Corrective Action Plans

Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements. To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions: 1. Procurement Policy Review with External Expertise: NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight. 2. Update and Alignment of Procedures: With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals). 3. Ongoing Education and Training: NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance. 4. Internal Controls and Review Process: A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action. 5. Monitoring and Quarterly Compliance Checks: The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight. Timeline for Implementation: • External Consultant Engagement: Completed – May 2025 • Policy and Procedure Review: To be completed by July 31, 2025 • Initial Staff Training: To be conducted by August 15, 2025 • Internal Controls & Monitoring: To be fully implemented by August 31, 2025 • Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter Anticipated Full Compliance Date: August 31, 2025 Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004) Responsible Party: Chief Financial Officer, Carlett Gregory

Condition: A weakness existed in the overall reconciliation/tie-in procedures performed over the Tribe’s financial statement accounts for the fiscal year ended September 30, 2024. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included: A)   Beginning Balances B)    Account Receivables C)    Grant Receivables/Unearned Revenues D)   Accounts Payable E)    Payroll and Other Current Liabilities Recommendation: The Tribe should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. Action Taken: We agree with the auditor’s recommendation. We expect this to be complete within 120 days past the issuance of this report

Condition: Prisma Health's written procurement policy and procedures are not compliant with the requirements of the Uniform Guidance (2 CFR Part 200). This includes the absence of a documented policy outlining the different procurement methods, related thresholds, necessary documentation, and steps to ensure full and open competition when using federal funds. Planned Corrective Action: Prisma Health acknowledges this finding and will develop and implement a Uniform Guidance compliant procurement policy within the next month. The policy will be reviewed and approved by the CFO, head of Procurement and representatives of the Grants team. Contact person responsible for corrective action: Matt Elsey, Executive Vice President and CFO Anticipated Completion Date: 7/31/2025

2024-03: Lack of Procurement Policy Contact Person Heather Ferebee Corrective Action Plan A procurement policy will be developed and approved by the City Council. Completion Date 2025

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Moving forward, the district will perform a cost/price analysis for procurement in excess of $250,000.

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process The district has also since enrolled with Bonefish, a partner of OASBO and Ohio Schools Council (OSC) to satisfy all requirements of securing vendors/entities using the Federal government’s System for Award Management (SAM). This will create the proper internal controls that were lacking.

Corrective Action Plan Actions Planned – The City will hold pre-meetings with grant administrators to ensure all federal compliance requirements are met including verifying suspension and debarment. Official Responsible – Amy Sevig, Deputy Finance Manager Planned Completion Date – December 31, 2025 Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – Janet Burns, Grant Coordinator Accountant, will oversee the process to ensure pre-meetings are set up with grant administrators and the City is in compliance with all federal grant requirements.

Finding 2024-001: Procurement, Suspension and Debarment Corrective Action: Management agrees with the finding. In fiscal year 2024 the Laboratory charged a federal sponsored award for a procurement item, which exceeded the Laboratory’s micro-purchase threshold, without maintaining the proper documentation as required by Laboratory procurement policy. In fiscal 2025 this item was identified by the Laboratory’s Internal Audit and Sponsored Programs Accounting Offices as part of their routine review program. The transaction cost was removed by Laboratory Management from the federal award within 90 days of the item's discovery; however, because the item was identified and adjusted in 2025, the fiscal year 2024 Schedule of Expenditures of Federal Awards (SEFA) was overstated. To ensure compliance with the Laboratory’s procurement policies the Laboratory has implemented and/or will implement certain corrective actions as detailed below, in line with the recommendation: Corrective Actions Previously Implemented: 1. The Laboratory’s Internal Audit and Sponsored Program Accounting Offices will continue to conduct regular reviews of procurement items to ensure that documentation complies with Laboratory Procurement Methods Policy and Procedure, to ensure compliance with Laboratory policy, designed to ensure compliance with 2 CFR Sections 200.317 through 200.327. The audit focus will continue to be on 100% of sponsored award procurement transactions in the small purchase threshold. 2. The Laboratory Information Technology department, in collaboration with the Laboratory’s Procurement Office Director, enhanced certain systemgenerated reporting to allow for easier identification by Procurement Office personnel of charges to sponsored awards. Corrective Actions to be Implemented: 1. The Laboratory’s Sponsored Programs Accounting Office, in collaboration with its Procurement Office, will provide an annual re-education to Laboratory administrative research personnel concerning Laboratory Procurement Policies, designed to ensure compliance with 2 CFR Sections 200.317 through 200.327. 2. The Sponsored Programs Accounting Office will provide re-training for administrative staff to reinforce the Laboratory Procurement Method Policies and Procedure. 3. The Director of Procurement will streamline access and visibility of the Procurement Methods Policy and Procedure on the Laboratory’s internal website. Management intends for the re-education of administrative research personnel and retraining for administrative staff to be concluded by the end of the third quarter and/or early fourth quarter of 2025. Management intends to provide for streamlined access and visibility of Laboratory Procurement Methods Policy and Procedure on its internal website prior to the end of 2025. Names of contact person(s) responsible for corrective action: Gerard Langlais, Corporate Controller

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained. Corrective Actions Taken or Planned MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions: Policy and Procedure Update As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file. Procurement Checklist Enhancement Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented. Training Implementation All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications. Ongoing Monitoring A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained. Contact Person Responsible Tariq Bahich Senior Director Finance Anticipated Completion Date Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.

Views of Responsible Officials: BCHC is in the process of composing a formal procurement policy, which will address requirements for open competition and establish thresholds for different procurement amounts/processes. The policy will clearly outline the conditions where a noncompetitive purchase is allowable. We anticipate having this policy written by June 1 and will submit to the BCHC Board for review and approval. I

May 27, 2025 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Re: Corrective Action Plan Regarding Section III: Schedule of Findings and Questioned Costs for the Fiscal Year Ended September 30, 2024, in Reference to 2024-001 Procurement It was identified in the findings of 2024-001 Procurement (repeat comment) that LCCMH had not followed proper procurement requirements and procedures regarding the agreement in reference to ALN 93.969 Certified Community Behavioral Health Clinics (CCBHC) expansion Grants. LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Thank you, Brooke Sankiewicz Chief Executive Officer Lapeer County Community Mental Health (810) 667-0500 bsankiewicz lapeercmh.org

Corrective Action Plan 2024-001: Management has since performed the suspension and debarment check for each vendor for which it used the on-call services contracts available. Additionally, management will include an addendum in future contracts to ensure vendor compliance with the federal contract regulations. Anticipated Completion Date: May 2025 Contact Person: Noelle Lewis, Chief Financial Officer

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200 and management's internal policies and procedures related to procurement, suspension, and debarment. Planned Corrective Action: Management agrees with the improvement of documentation of procurement, suspension, and debarment. As noted below, purchasing policies are being followed, but were not always formally documented. Careful consideration was done in selecting the vendors to look at obtaining the best cost for the value of the service as IWS was responsible for a portion of the expenses. The findings noted three procurement contracts that were more than $50,000 that did not properly document the rationale for selection and/or sole procurement. The first contract was a single source provider for the replacement of thermostats. Other heating and air conditioning vendors would not handle the replacement of the thermostats as it was not their equipment. There was also a preventative maintenance agreement with the vendor: Phoenix Heating and Air. We will document the use of a single source contractor as allowed in our purchasing policies. We did follow the other control procedures regarding contract approvals, obtaining Certificates of Insurance and verifying completion of the work. The second contract was related to our website and marketing company: Brand Vibe. We did an open bid process, two years earlier, and renewed the contract without a formal bid process. As mentioned above, we did follow the proper approval process and verified the work was completed. The total of this contract for FY 2024 was $74,665, however only $3,600 was charged against the federal grant. Going forward, we will document the rationale for renewing the contract. The third contract was for a bi-lingual APN, with a Psych. Certificate, who was a former employee. She wanted to work part-time, and we switched her to a 1099 employee. With her experience and work record, we allowed her to transition to a part-time contractor. Our experience finding bi-lingual providers has been difficult, and the agency costs are almost double the cost paid for this contractor. The amount charged to the Trauma-Informed Centers of Care was $47,769. In the future, we will formally document the selection and use of this contractor. As noted, we did have a formal contract. and all providers are approved by the Board. Management will make necessary revisions to the existing procurement processes and controls in a timely manner to ensure that procurement decisions are documented, as required by 2 CFR Part 200. Specifically, management will ensure the history of procurement - whether obtained through quotes, formal competitive bids, or through non-competitive means – is documented, including evidence that a cost-price analysis was performed for all purchases in excess of the simplified acquisition threshold. Additionally, before entering a covered transaction with third parties, management will have a form completed by the outside parties stating they are not suspended or debarred from engaging in federal activity before entering a covered transaction. This form will be retained, and we will check and document Sam.gov, excluded parties listing. Contact person responsible for corrective action: Karen L. Williams, Chief Financial Officer Anticipated Completion Date: 06/30/2025

Action taken: Management has updated the process to verify that contractors are not suspended or debarred from receiving federal funds. While management was previously reviewing and confirming contractor eligibility, this confirmation was not consistently documented in the contractor records. Effective immediately, management has implemented a new step requiring the inclusion of a physical screenshot from SAM.gov in the contractor records. This adjustment ensures proper documentation and alignment with compliance requirements. Person responsible: ShaQuina Davis, Chief Operating Officer Date completed: February 10, 2025

U.S. Department of Treasury Central Arizona Irrigation & Drainage District respectfully submits the following corrective action plan for the year ended December 31, 2024. Audit period: January 1, 2024 - December 31, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY 2024-001 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. Recommendation: We recommend the District design controls to ensure an adequate review process is in place to ensure potential contractors are in compliance with the Uniform Guidance procurement rules and procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District's policies will be updated and approved if needed to confirm to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager, Derek McEachern, Deputy General Manager, or Delia Stoor, Accounting Manager. Planned completion date for corrective action plan: September 30, 2025. If the U.S. Department of Treasury has questions regarding this plan, please call Ron McEachern, General Manager, Derek McEachern, Deputy General Manager, ot Delia Stoor, Accoutning Manager at 520-466-7336.

Finding 2024-002 – The Organization’s current documented procurement policy does not contain all the required elements identified within the Uniform Guidance. 2024-002 Recommendation: The Organization should adopt a formal procurement policy that complies with 2 CFR 200, Sections 200.318 through 200.327. Action Taken: Management agrees with the finding and will review the requirements under the Uniform Guidance relating to procurement and establish a formal policy and related procedures to comply with those requirements. Expected Date of Completion: June 30, 2025

In the future the Treasurer will ensure proper procurement methods are utilized.

Finding 2024-002 Department of Transportation Airport Improvement Program, CFDA #20.106 AIP3 46 0050 59, AIP3 46 0050 62, AIP3 46 0050 63, and AIP3 46 0050 64 Finding Summary: The SF-425 annual report dated September 30, 2024, for award AIP3 46 0050 64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. Responsible Individuals: Dan Letellier, Executive Director Corrective Action Plan: Management will ensure correct support documentation is provided to 3rd party account for correct submission of FAA Forms 5100-127. Director will also verify that annual report form SF-425 reconciles to underlying supporting records. Anticipated Completion Date: Ongoing

Finding 2024-010 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295-01-01 Year: 12/01/2022 – 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

Finding 2024-002 Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Year: 2024 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Department’s Management Response: Ventura County Health Care Agency (VCHCA) Management agrees with the recommendation for the County to strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. View of Responsible Officials and Corrective Action: VCHCA Management will implement documentation procedures to support the evaluation and selection of vendors. These procedures will include, but are not limited to, ensuring that debarment and suspension verifications are properly documented and retained, procurement transaction histories are maintained in official records, and all contracts include the applicable provisions required under 2 CFR 200 Appendix II. Name of Responsible Persons: Mike Taylor, HCA CFO Theresa Cho, HCA Director Implementation Date: June 2025

Beginning in FY2025, the Department of Human Services (DHS) Office of Procurement Services (OPS) began reviewing new contracts in the new contracting system, Contract Lifecycle Management (CLM) System for compliance with State Procurement Rules and Regulations. In addition, OPS will extend the review to include all contract requests (new, amendments, extensions, and renewals). During the additional review, OPS will inform the program of any requests that are not in compliance with the Procurement Rules and Regulations before the contract is fully executed. OPS also reviewed prior contractual amendments, extensions, and renewals within the CLM System at the requisition level for compliance with the State Procurement Rules and Regulations. If an infraction was found, the program was notified and informed of the State Procurement Rules and Regulations.

Friday, April 11, 2025 Dear Sir(s): CORRECTIVE ACTION PLAN In prior years the accounting of Pyramid Learning Corp. was executed externally by a contracted accounting company. During the year ended June 30, 2024 we acquired a specialized accounting software. After the acquisition of the new software, we recorded the data from the beginning of the year to the present, which required significant staff effort and made it impossible to maintain accounting and financial reports on a month-to-month basis. At the present, the data is already being recorded, and the accounting is up to dates. This allows us to keep our accounting and interim financial reports such as Balance Sheet, Statement of Activities, Bank Reconciliations, and monthly analysis of accounts, up to date and on a current month-to-month basis to be more transparent, and any errors are corrected on a timely manner.

Condition: The Organization did not have documented procurement procedures that were consistent with the standards identified in 2 CFR 200.318(a). Recommendation: Management should draft a formal procurement policy outlining the Organization’s procedures in a manner consistent with the standards identified in 2 CFR 200.318(a). Planned Corrective Actions: The Organization agrees with the finding and plans to carry out the recommendation noted above by May 31, 2025.

Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2025.

Failure to Follow Procurement Policy Finding 2023-003 Auditor Description of Condition and Effect: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). As a result, the Authority is noncompliant with 2 CFR 200 and its own procurement policy. Auditor Recommendation: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Corrective Action Plan: The Authority acknowledges the finding and is currently working to correct this. Responsible Official: Contact person is Todd Shurn, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2025