Corrective Action Plans

Corrective Action Plan The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Individual(s) Responsible Sherry Bradley Completion Date Discussion is ongoing regarding the plan; it will be implemented by the end of 2025.

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026

FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025

Following the close of the 2023 audit in October 2024, 9/11 Day implemented a strengthened procurement process for all large vendors, including the adoption of a formal procurement policy that complies with federal guidelines. A vendor log and checklist system has been established to document the receipt of RFPs, the rationale and method of procurement, and decisions on whether to move forward with a vendor. Although 9/11 Day has, and does verify whether vendors and subgrantees are permitted to receive federal funds, we have now updated our policy to retain printed verification of each vendor’s/subgrantee’s eligibility to receive federal funds, including confirmation that these organizations are not suspended or debarred. These documents will be retained in the procurement file for each vendor/subgrantee. These steps ensure compliance with 2 CFR 200.318 and provide clear documentation and oversight for all procurement activities.

FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Timothy Detrick – Clerk-Treasurer Contact Phone Number and Email Address: treasurer@townoffrankton.in.gov Views of Responsible Officials: Concur with the finding Description of Corrective Action Plan: I’ve already spoken with our Council President regarding the creation of an ordinance to establish a formal Procurement Policy, that mimics state law that’s already established. This ordinance will ensure that all new contracts entered into by the Town comply with Build America, Buy America (BABA) requirements. The ordinance will also ensure that the Town verifies both current and prospective vendors through the SAM.gov website to confirm their eligibility to receive federal funding. The ordinance will have in it that BABA must be follow and the town will verify that the contract is in good standing with the state but checking the SAM.gov website. Once check an affidavit will be made stating that that are in good standing, and signed by the council president and Clerk-Treasurer. Anticipated Completion Date: End of 2025 Date December 31st, 2025 INDIANA STATE

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Health System is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Health System will create a procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. Contact Person: Daniel Cooper, Vice President of Finance and Accounting Expected Completion Date: December 31, 2025

Management will continue strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. Purchase orders will no longer be included in any submissions. Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained.

FINDING 2024-002 Material Weakness-Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Brittany Couse Contact Phone Number: 765-677-2014 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Clerk Treasurer's Office will continue to check the System for Awards Management quarterly to verify any contractor is not debarred. Further, the office will now check for contracts that exceed the $25,000 threshold that require such inquiry. Anticipated Completion Date: Immediate

WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding contractual provisions and procurement. Additional training has been provided and completed by management and staff. The fiscal policy manual procurement section will undergo further review by a third party and if recommended, will be updated and presented to the Finance Committee of the Board of Directors.

FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings of this report. Description of Corrective Action Plan: The County Highway Department has implemented a new filing system to help ensure that audit documentation is being maintained for all federal requirements. The County will maintain documentation of all bids and Letter of Interests (LOIs) received from vendors for each project for review. These files are maintained in their own folder with the DES# and project description on the outside. The County will also maintain documentation of the LPA Selection Review Checklist for each project for review. The County Highway Superintendent is responsible for maintaining all the files and the administrator will review/sign the checklist to ensure all the files are properly maintained. In addition, the County is currently working with the County's attorney to develop a procurement policy that includes federal regulations. Anticipated Completion Date: September 2025

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

View of Responsible Official The Executive Director will take action to make sure USDA reports are filed on time. The ED will work with the Finance Director and other accounting staff to ensure deadlines are met. Timeline Target implementation September 30, 2025. Staff Responsible Executive Director

FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has a longstanding contractual relationship with an engineering firm with extensive knowledge of the City’s water department. The city has put controls and procedures in place to ensure services are bid where federal awards are involved and the dollar amount of such services is expected to exceed the simplified acquisition threshold. The City will review its procurement policy and amend where necessary to conform to the current requirements of CFR 200.318. The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. Anticipated Completion Date: January 1, 2026

FINDING 2024-001 Finding Subject: Department of Transportation Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Brad King Contact Phone Number and Email Address: 765-648-6171 bking@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. The City has implemented procedures to ensure the proper documentation of quotes taken where applicable. Anticipated Completion Date: September 1, 2025

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the federal program: • One instance where the Cooperative followed a bid process, however, the documentation was not retained to support the selection. Additionally, the contract with the vendor was missing required contract provisions in accordance with Uniform Guidance. • Two instances where the Cooperative did not follow the procurement process as detailed in the procurement policy and did not have any formal documentation or contract in place with the vendor. • Three instances where the Cooperative entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Corrective Action Plan: We plan to review our procurement policy with all parties that may enter into contracts for the cooperative to be sure the policy reflects our needs and that procedures are being followed. We will also implement a review process where management signs off on bid selection documentation, including verification that vendors are not suspended or debarred. Responsible Individuals: Hollee McCormick, General Manager and Jason Troendle, Director of Operations and Engineering Anticipated Completion Date: November 2025

2024-005 Improve Internal Controls Over Procurement Management Response and Corrective Action Plan (DPW): Management concurs with the finding. The City acknowledges that one procurement, a rental for a piece of equipment under the SLFRF program for ARPA Replacement Roads and Sidewalks, lacked sufficient supporting documentation to demonstrate compliance with federal procurement standards. The City is committed to strengthening internal controls to ensure all federally funded procurements comply with 2 CFR 200.317–200.327, Treasury’s SLFRF Compliance and Reporting Guidance, and applicable state and local procurement laws. Planned Implementation Date: 12/17/2025 Person Responsible for Corrective Action: Julianne Pelletier

Health Resources and Services Administration Mary Zelazny, Finger Lakes Migrant Health Care Project, Inc.’s CEO respectfully submits the following corrective action plan for the year ended December 31, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2024 Item 2024-002 – Reporting (Significant Deficiency) The Project did not maintain documentation evidencing management's review of the Federal Financial Report (SF-425) prior to submission. Although the reports were submitted timely, there were no indication of formal review procedures to validate the accuracy, completeness, or consistency of reported financial data with the accounting records. Recommendation We recommend that the Project establish and implement a formal review process over the Federal Financial Report (SF-425); we also recommend that evidence of the review be documented and approval be kept on file. Action Taken Management agrees with the finding and will be implementing formal review procedures including documented evidence of review and approval prior to submission. Effective Date: September 1, 2025

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, reporting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Controller's office will provide instruction for all departments on retrieving letters from their vendors. This training is crucial for ensuring compliance with Suspension & Debarment regulations and establishing a robust system of internal controls for federal funds. Anticipated Completion Date: December 31, 2025

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.

Contact Person (s): Jim McCarthy - jim@waterwatch.org ; Neil Brandt – neil@waterwatch.org Corrective actions planned: The following corrective actions are being immediately implemented for contracts in WaterWatch’s restoration program in order to achieve compliance: 1. Language requiring all contractors to comply with the Build America, Buy America (BABA) Act is added to all new WaterWatch contracts and all current contracts via amendment. 2. Language requiring all contractors to comply with federal suspension and debarment contracting standards is added to all new WaterWatch contracts and all current contracts via amendment. 3. WaterWatch will keep formal documentation of debarment searches for all contractors. 4. WaterWatch will keep formal documentation of contractor procurement process in both Southern Oregon and Portland offices. Anticipated completion date: September 1, 2025