Corrective Action Plans

Finding 2024-005 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Nate Moore, Finance Director Corrective Action: The Finance Department will regularly ensure that the procurement policy for the City is followed, and will be sure that it is reviewed often to be sure that no modifications or adjustments need to be made. Anticipated Completion Date: June 30, 2026

The executive level, including the finance director of SEVCA, acknowledge these weaknesses in our practice in FY24. SEVCA has renewed focus on well documented proper procurement procedures and accountability for oversight of procurement action steps by multiple team partners. The following corrective actions are in place: 1. Policy Reinforcement and Training o Conducted mandatory training for all staff involved in procurement, emphasizing the documentation requirements outlined in the Organization’s procurement policy.o Distributed updated procurement documentation checklists to ensure clear understanding of required elements for each procurement file. 2. Standardized File Documentation Process o Implemented a standardized cover sheet or checklist for each procurement file to be completed and reviewed before contract finalization. This indicates whether all required steps (e.g., solicitation of bids) were completed or, if not, the reason for deviation in standard practice. 3. Internal Review and Monitoring o Established a quarterly internal review of a random sample of procurement files to ensure compliance with documentation standards. o Assigned a staff member or team (e.g., Finance Support Specialist) to oversee this review process and report findings to Finance Director and Program Director. 4. Follow-Up and Accountability o Require program director and finance director sign-off on all procurement files over $20,000 to ensure all documentation requirements are fulfilled. o Include procurement documentation compliance as part of staff performance evaluations where relevant. Responsible Person: Finance Director, Lisa Whitney and Executive Director, Josh Davis

Description of Finding: Reporting - Significant Deficiency in Internal Controls Over Compliance and Noncompliance · Criteria: In accordance with 2 CFR 200.328 (Uniform Guidance), recipients of federal funds must file complete, accurate, and timely financial reports using the prescribed standard reporting forms (e.g., SF-425). These reports must be supported by the recipient's underlying accounting records and signed by authorized personnel. · Condition/Context: The Tribe was unable to provide documentation demonstrating that the required Federal Financial Report (FFR) for the year ended September 30, 2024, was submitted. As a result, the auditors could not determine whether FFR was filed in a timely manner or whether it included the proper authorization signature. · Cause/Effect: The apparent lack of formal procedures or controls for retaining evidence of FFR submissions contributed to the unavailability of supporting documentation. The absence of evidence of submission and authorization could result in noncompliance with federal reporting requirements. If the report was not submitted timely or was not signed by authorized personnel, the Tribe may be subject to adverse consequences, including potential questioning of costs, additional oversight, or delays in future funding. Statement of Concurrence or Nonconcurrence: Tribe agrees with the finding as stated by the auditors. Corrective Action: The Tribe has drafted a comprehensive Financial Management Policies and Procedure Manual, which includes a section specific to grants management and procurement, that will provide guidance for month end close, asset management and preparation of the Schedule of Expenditures of Federal Awards. Reporting, etc. The Financial Management Policies and Procedure Manual will be presented to the Tribal Council for review and adoption by December 2025. Additionally, the Tribe has a third-party CPA firm to conduct mandatory Uniform Guidance training and regular grant compliance and accounting training for all program and accounting staff working with grant awards. Persons Responsible: Leslie Williams, Senior Vice President of Finance Wendy Collazo, Executive Director of Accounting - Tribal Government Name of Contact Person: Leslie M. Williams Senior Vice President of Finance Leslie.williams@29palmsbomi-nsn.gov 760.984.4514 Sincerely yours, Lapoli( W/. William) Leslie M. Williams Senior Vice President of Finance

Written procedures and conflict of interest policies in accordance with the Uniform Guidance will be established and implemented during the year ended June 30, 2026.

2024-002 Finding Subject: COVID 19: Coronavirus State and Local Fiscal Recovery Funds - IFA Grant - White Ditch– Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources. Description of Corrective Action Plan: All purchases need to be made in accordance with the Sanitary District of Michigan City Purchasing Policy. All contracts will be supported by a written and signed contract document per Section 9.0 of the Sanitary District of Michigan City Purchasing Policy. Suspension and Debarment 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Description of Corrective Action Plan For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025

FINDING 2024-001 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources Description of Corrective Action Plan: All purchases need to be made in accordance with the City of Michigan City Purchasing Policy. Purchases made under the Special Purchase provision (I.C.5-22-10-1) will abide by section 7.4 of the Michigan City Purchasing Policy. This section describes the required record keeping. Suspension and Debarment Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.320 states in part: (a) "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . Description of Corrective Action Plan: For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025 INDIANA STATE

Federal Award Findings Finding 2024-003 U.S. Department of Treasury Passed through State of South Dakota Board of Water and Natural Resources Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The City does not have a formal documented procurement policy which includes written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts with federal funds . Responsible Individuals: Mike Steen, Mayor and Amanda Metzinger, Finance Officer Corrective Action Plan: Management plans to formally document and approve an official written procurement policy that follows all necessary state and federal laws, including the required procurement standards within 2 CFR sections 200.318 through 200.327. Anticipated Completion Date: 9/22/25

FINDING 2024-004 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately, which will include implementing a federal procurement policy. The Auditor will start checking all vendors paid from grants for suspension, debarred or excluded from being able to enter into contracts. Anticipated Completion Date: August 30, 2025

Retrained all staff on procurement policies – the approver misunderstood and thought that because this was a reimbursed cost that the higher level signature was not needed, so we have clarified that approval limits apply regardless of whether it is a reimbursable cost Establishing new, more automated procurement approval process that allows us to set approval levels for each user and will reduce potential for errant approvals Ensure all new management staff receive and acknowledge the procurement policy

FINDING 2024-002 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Thomas A. Dippel, CPA Contact Phone Number and Email Address: (812) 683-2211 / ct@huntingburg-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with the City’s attorney to revise its current policy to include federal regulations and procedures related to Procurement and Suspension and Debarment. Once revised, the City will follow its policy to ensure compliance with the compliance requirement. Anticipated Completion Date: September 30, 2025

Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Federal Financial Assistance Listing #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified the following • The Cooperative’s formally documented procurement policy was missing one required element as it relates to the methods of procurement. • 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 • One instance 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. • Two 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: The Cooperative has taken several steps to remedy the findings of the 2024 single audit: • In April 2025, the Board of Directors approved a revised procurement policy that includes the missing method of procurement. • Existing contracts have been amended to include required contract provision in accordance with Uniform Guidance. Any new contract will include those provisions. • All current contractors have been reviewed to ensure the vendors are not suspended or debarred. All searches have been printed and retained. Any new contractors will be reviewed prior to their selection as a vendor. • The reasoning for utilizing single-source vendors has been formally documented and signed off on by management. • All bid processes are now formally documented, including cost comparisons between vendors. Responsible Individuals: Jeremy Richert, CEO and Kelly Gibbs, CFO Anticipated Completion Date: July 2025

Corrective action planned: Two new policies will be implemented; a board policy to cover board approvals for the bidding of large projects and an internal policy and procedure which spells out additional requirements, like requiring three written bids for large purchases. In addition, all members of the Board of Directors and senior leadership team will sign Conflict of Interest statements on an annual basis to confirm that they do not have any potential conflicts that could impact purchasing decisions. Anticipated completion date: July 31, 2025 Contact person responsible for corrective action: Steve Lindemann, Interim CFO

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Department of Homeland Security and Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: The Cooperative's procurement policy had not identified the dollar thresholds of procurement within the methods of procurement. In addition, one contract selected for testing was missing one of the required contract provisions. Corrective Action Plan: The Cooperative is working with our attorney to update the procurement policy to include the dollar thresholds of each method of procurement. We will update the procurement policy after acceptable changes are made. Responsible Individuals: Shelly Hove, CFO Anticipated Completion Date: September 2025

Identification Number: 2024-001 Finding: Procurement, Suspension and Debarment Corrective Actions Taken or Planned: The Armed Services YMCA (ASYMCA) acknowledges the control deficiency identified in the area of procurement policy and is actively addressing it to ensure full compliance with 2 CFR § 200.318 (formerly referenced as 2 CFR 300.218), which governs procurement standards for non-federal entities receiving federal awards. 1. Policy Development and Alignment with Federal Regulations ASYMCA Finance is currently compiling and formalizing procurement procedures in accordance with 2 CFR § 200.318. This initiative will result in a comprehensive, board-approved procurement policy that ensures compliance with federal requirements and strengthens internal controls. 2. Existing Policies and Controls ASYMCA already maintains consistent, documented, and approved policies in several key areas of procurement and financial management, including: • Authority of Responsibility: Delegation of authority for designating funds and obligating ASYMCA for purchases, including spending thresholds and approved personnel. • Procurement Standards: General procurement principles and internal controls. • Professional Services and Consulting Agreements • Purchase of Capital Items • Signature Authority • Legal Review • Unbudgeted Expenditures • Record Retention • Policy Enforcement and Consequences • Procedures for Invoicing, Payment Processing, and Reimbursements (Travel and Non-Travel) • Requesting New Vendors • Competition: Requirements for full and open competition in vendor selection.   3. Areas for Expansion and Integration To ensure full compliance with federal procurement standards, ASYMCA will expand its current policies to include the following areas: • Conflict of Interest: Clear guidelines to prevent personal or organizational conflicts in procurement decisions. • Methods of Procurement: Defined procedures for micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals. • Purchase/License of Technology or Software: Standards for evaluating and acquiring digital tools and platforms. • Indirect Cost: Clarification of treatment and allocation of indirect costs in procurement. • Methods of Procurement (as per federal thresholds) • Contracting with Small and Minority Businesses and Women’s Business Enterprises • Contract Cost and Price Analysis • Federal Awarding Agency Requirements 4. Implementation Timeline ASYMCA is committed to finalizing, approving, and implementing the updated procurement policy the end of the 2025 reporting period. This will include: • Internal review and legal vetting (if necessary) • Board and/or Audit Committee approval • Staff training and dissemination of the policy • Integration into operational procedures for all federally funded and non-federally funded projects Conclusion ASYMCA is committed to maintaining the highest standards of accountability, transparency, and regulatory compliance. The actions outlined above demonstrate a proactive and structured approach to addressing the control deficiency and ensuring that all procurement activities are conducted in accordance with applicable federal regulations. Anticipated completion date: December 31, 2025 Responsible Contact Person: Laura Tate-Smith, Chief Financial Officer

Corrective Action Planned: The USGA will enhance the procedures within its Policy for the Acquisition of Goods & Services relating to procurements utilizing Federal funding. In particular, the Policy will be amended so that adequate documentation is retained to ensure compliance with the requirements for the procurement methods described in 2 CFR §200.320. Further, the updated Policy will include additional requirements to ensure that applicable documentation of the USGA’s suspension and debarment verification procedures is retained and attached to any related purchase order in the USGA’s ERP system. At the time of the Policy’s approval by the USGA’s Executive Leadership team, the document will be shared with all employees and posted on our internal shared site where Finance related policies are stored and may be referred to. The USGA’s Finance/Accounting Department will be responsible for identifying grants to which the updated Policy applies and to assist with retaining the relevant documentation. The USGA’s Finance/Accounting Department will also develop a unique coding/project identifier to assist with ensuring that the request to purchase via a Purchase Order (PO) is visibly different than a generic PO when Federal funding is involved.

The County Board should draft and approve policies and procedures for the procurement of contractors per the Compliance Supplement, Code of Federal Regulations, United States Codes, and Federal Acquisition Regulations to ensure the proper advertisement and selection of contractors and consultants, and to prevent conflicts of interest during the selection of contractors and consultants. Management Response: Management will draft and approve the recommended procurement policies and procedures and disseminate the information to department heads and County employees during the fall of 2025.

Finding 2024-003 – Material Weakness Award No.: AL No. 15.555 and AL No. 15.074 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The following conditions were noted during the single audit: • The District was not able to provide evidence that procurements for the Mendota Pool Fish Screen and Control Structure Project and Poso Canal Bridge Replacement Project design contractors under AL 15.555 met the requirements for adequate price competition and was unable to provide documentation confirming the sole-source solicitations met the requirements of Uniform Guidance. Specifically the District was unable to provide evidence it received enough statements of qualification to have adequate price competition or complied with one or more provisions of Section 200.210(c) that allows a sole source agreement to occur. It would appear the District would need evidence that the grantor approved the sole source procurement, but was not able to provide documentation of approvals of sole source procurements by the grantors. The District also was unable to provide documentation of the advertisement of the solicitation of requests for qualifications for the Fish Screen and Control Structure Project. • The District was not able to provide adequate documentation that the Mendota Pool Fish Screen and Control Structure Project contract under AL 15.555 and Orestimba Creek Recharge and Recovery Expansion Project contract under AL 15.074 complied with Section 200.327 and appendix II to this part requiring federal contract provisions to be included in the approved contract. This resulted in the District not having evidence that the contractor certified it was in compliance with all required federal provisions. Criteria: Uniform Guidance states the following: • Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractors selection or rejection, and the basis for the contract price.” • Section 300.320(c) states “There are specific circumstances in which the recipient or subrecipient may use a noncompetitive procurement method. The noncompetitive procurement method may only be used if one of the following circumstances applies: (1) The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The procurement transaction can only be fulfilled by a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation; (4) The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency or pass-through entity provides written approval; or (5) After soliciting several sources, competition is determined inadequate. • The provisions of the Brooks Act (49 United State Code, Section 1104) require local agencies to award federally funded engineering and design related contracts, otherwise know as A&E contracts, on the basis of fair and open competitive negotiations, demonstrated competence, and professional qualifications (23 Code of Federal Regulations (CFR), Part 172) at a fair and reasonable price (48 CFR 31.201-3). Both federal regulation and California state law (Government Code 4525-4529 et a) require selection of A&E consultant services on the basis of demonstrated competence and professional qualifications. Procurement by noncompetitive proposals may be used only when the award of a contract is infeasible under small purchase procedures, sealed bids or competitive proposals, as cited above. • Section 200.327 states “The non-federal entity’s contracts must contain the applicable provisions described in appendix II to this part.” Appendix II contains requirements to include in federally funded contracts termination for cause and convenience provisions, Equal Employment Opportunity provisions, Davis-Bacon Act provisions, Contract Work Hours and Safety Standards Act provisions, Clean Air Act provisions, debarment and suspension provisions, Byrd Anti-Lobbying Amendment provisions, and other provisions, as applicable. Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the requirement to maintain documentation indicating the procurement was in compliance with Uniform Guidance Sections 200.318 to 200.327 and appendix II to this part. Context: The original procurement for the consulting firm for the Mendota Pool Fish Screens and Control Structure project was performed in September 2018 and awarded in late October 2018. This procurement precedes the current staff. Staff indicated the grantor approved the Mendota Pool Fish Screen and Control Structure Project sole source procurement and the Board Resolution approving the agreement indicated the grantor approved the sole source procurement, but staff was not able to provide proof of written approval by the grantor. Recommendation: We recommend management implement additional controls over the procurement process that ensures each procurement complies with Uniform Guidance Section 200.318 to 200.326, including training of staff working on procurements of the documentation retention and other requirements under the Uniform Guidance. We further recommend the District establish a procurement folder on its server with subfolder for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals/qualifications with language that satisfies Uniform Guidance requirements, proposals received, executed contracts, certifications of compliance with federal contracting provisions by the contractor if not part of the proposal or executed contracts, documented quantitative and qualitative analysis indicating why the recommended bid was selected for approval, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. If a sole source procurement method is used, documentation showing the sole source procurement is allowable under criteria listed in Section 300.320(c) should be retained. Views of Responsible Officials and Planned Corrective Actions: Management will keep procurement folders on each procurement in the future that includes the confirmation in the recommendation and will consult with Reclamation on whether a contract amendment is necessary to document the federal contract. Estimated Completion Date of Corrective Action: Future procurement projects

Finding: Procurement, Suspension and Debarment: Special Education – Special Olympics Education Programs The recipient must maintain and use documented (written) procedures for procurement transactions under a Federal Award or subaward, including for acquisition of property or services. These documented procedures must be consistent with applicable State, and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in the Uniform Guidance (2 CFR 200.317-200.327). The Organization has a written purchasing policy in place, but it does not include all required elements for a procurement policy in accordance with Federal statutes . Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding. Management will review the organization’s current Procurement Policy and make adjustments to the policy to ensure that it contains the required criteria to meet the federal procurement guidelines. An updated copy of the organization's Procurement Policy will be finalized by Oct 31, 2025. This policy will be reviewed regularly to ensure that it remains in compliance with federal procurement guidelines. Responsible Official: Greg Vanselow, Chief Operating Officer Completion Date: Oct 31, 2025

The city has updated and implemented its procurement process in FY25 to ensure that expenditures for vendors that exceed $10,000 and sole source contracts follow the correct procurement policies and procedures in accordance to MGL 30B.

The City will update it’s polices and procedures to help ensure the procurement standards are followed when expending federal monies.

Correction action • Finance team is in the process of implementing a new financial accounting (Grants Management System, Sage) system to ensure that coding for grants are accurately tracked. Internal reports will be built to provide monthly analysis of individual grants. Finance will work with program staff to ensure timely and accurate budget to actuals review and reconciliations. • Finance will contact Grant Manager responsible for each grant to develop plan of action for returning any overdrawn funds. Responsible Person • Associate Director - Finance Anticipated completion date • September 30, 2025

FINDING 2024-03 Finding Subject: Water and Waste Disposal System for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The Clerk Treasurer will work with the council and town attorney to make sure we are following the procurement policy and that we are compliant with the Federal and State guidelines. If a new project or a current project is being extended to a significant amount; during a council meeting, we will state that we are retaining a certain vendor for the project and explain why we are using that vendor. Anticipated Completion Date: August 1, 2025

CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-004 Procurement and Suspension & Debarment Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds In accordance with 2 CFR 200.318, non-Federal entities must have and use documented procurement procedures, consistent with State and local regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. The Organization's procurement policy requires obtaining three competitive bids for purchases in excess of $5,000 before purchase order is placed. In addition, it states that CFR 200's procurement standards are the guiding legislation. The Organization did not have adequate documentation to support the Organizations procurement decisions and did not have adequate internal controls in place which resulted in a purchase without adherence to the Organization's own procurement policies and the Uniform Guidance. CLIENT PLANNED ACTION: 1. SummitStone will review and align its procurement policy with Uniform Guidance compliance requirements for procurement records per 2 CFR 200.318 (i) Procurement records as well as 2 CFR § 200.214 Suspension and debarment requirements. 2. SummitStone will provide the necessary training on Uniform Guidance procurement compliance requirements to its procurement personnel and other authorized purchasers within the organization. 3. SummitStone will update its purchasing procedures and record keeping thereof, to ensure that competitive bids are obtained prior to contract / purchase order issuance / q CLIENT RESPONSIBLE PARTY: John Dowling, Chief Financial Officer Sarah Bystrom, Director of Compliance COMPLETION DATE: September 30, 2025

SINGLE AUDIT FOR THE YEAR ENDED SEPTEMBER 30, 2024 CORRECTIVE ACTION PLAN FEDERAL AWARD FINDINGS - Fiscal Year 2024 Finding Number: 2024-001 Procurement Assistance Listing Number: 93.696 Assistance Listing Title: Certified Community Behavioral Health Clinics N ame of Federal Agency: Substance Abuse and Mental Health Services Administration Federal Award Identification Number: H79SM089299 Fiscal Year of Initial Finding: 2024 • Name of the contact person: Tina Boyer, CFO • Corrective Action Plan: Management agrees with this recommendation. VBCMH management will review and update policies and procedures to ensure that allfederal requirements are followed. Anticipated Completion Date: Fiscal Year 2025

Finding: 2024-036 -A review of 25 FY 24 Disaster Grants payments found that 14 payments (56 percent) lacked required supporting documentation. Specifically, six payments lacked pay policy and/or fringe benefit calculations and eight payments lacked procurement contracts that included all federal requirements. Additionally, two of the eight payments lacked a complete or signed contract on file. Questioned Costs: AL - 97.036: $96,758; AL - 97.036 COVID-19: $2,159 Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants — Public Assistance (Presidentially Declared Disasters) Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DMVA concurs with the finding. Corrective Action (corrective action planned): To ensure compliance with federal regulations and effective management of federal awards, the Finance Office in conjunction with the Homeland Security Director will develop and implement written procedures that provide a clear framework for managing federal awards and ensure compliance with federal regulations. DMVA will: • Clearly outline federal requirements under 2 CFR 200.327, 2 CFR 200 .403(g), and Homeland Security Acquisition Regulation Class Deviation 15-01. • Specify the documentation required to support reimbursement requests, including expectations related to discrepancies and follow-up actions. • Outline the procedures for Homeland Security for reviewing and certifying work completed by contractors, where applicable, prior to reimbursement to subrecipients. Completion Date (list anticipated completion date): October 31, 2025 Agency Contact (name of person responsible for corrective action): Bryan Fisher