Audit 300045

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-004 U.S. Department of the Transportation Assistance Listing Number 20.205 WB&A Trail (highway Planning and Construction) Compliance Deficiency over Special Tests – Quality Assurance Program, Value Engineering, and Utilities Repeat Finding: No Criteria: A State DOT or Local Public Agency (LPA) must have a quality assurance (QA) program, approved by Federal Highway Administration (FHWA), for construction projects on the National Highway System (NHS) to ensure that materials and workmanship conform to approved plans and specifications (23 CFR sections 637.201, 637.205, 637.207, and 637.209). Recipients are required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate (23 USC 106(e); 23 CFR Part 627). Recipients are required to develop policies and procedures pertaining to the use, accommodation and/or relocation of public and private utility facilities on highway rights-of way using federal highway funds. Recipients are required to develop, maintain, and obtain FHWA approval of their Utility Accommodation Policy (UAP) (23 CFR section 645.215). Condition and Context: Management was unable to provide support documenting the County’s compliance with quality assurance program, value engineering, and utilities special tests for the year ended June 30, 2023. Cause: The County is a pass through entity, and believed the direct recipient of the award was responsible for these special tests requirements. However, there is no formal documentation of this understanding with the direct recipients of these responsibilities. Effect or Potential Effect: The County may not be in compliance with the special tests requirements under Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County formalize its agreement with the pass-through entity to clarify the responsibilities for the special tests requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-001 U.S. Department of Labor Assistance Listing Numbers 17.258, 17.259, 17.278 – WIOA Cluster Material Weakness over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). A PTE must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)), and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: The County did not conduct adequate monitoring of its subrecipient during the year ended June 30, 2023. The County passes 100% of WIOA Cluster funds to one subrecipient, and risk assessment or monitoring activities (site visits, financial reviews, or programmatic assessments) were not conducted to provide assurance of compliance with Federal regulations. Cause: The County did not perform subrecipient monitoring. Without established processes and dedicated resources for subrecipient oversight, the County was unable to fulfill its monitoring obligations effectively. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Additionally, we recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-002 U.S. Department of Housing and Urban Development Assistance Listing Number 14.218 – CDBG – Entitlement Grants Cluster Compliance Deficiency over Reporting Repeat Finding: No Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition and Context: The County is a direct recipient of CDBG Entitlement Grants Cluster funds from the Department of Housing and Urban Development. Additionally, the County provided first-tier subawards greater than $30,000. Cause: The County did not report its first-tier subawards in accordance with the Transparency Act requirements. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 N/A N/A N/A Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $4,605,932 $4,604,932 N/A N/A N/A Effect or Potential Effect: The County was not in compliance with the reporting requirements of the grant. Questioned Costs: None. Recommendation: We recommend the County establish and implement controls to maintain compliance with reporting requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-003 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Compliance Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2022-001 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). A PTE must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Condition and Context: For 1 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.332(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.

Finding 2023-004 U.S. Department of the Transportation Assistance Listing Number 20.205 WB&A Trail (highway Planning and Construction) Compliance Deficiency over Special Tests – Quality Assurance Program, Value Engineering, and Utilities Repeat Finding: No Criteria: A State DOT or Local Public Agency (LPA) must have a quality assurance (QA) program, approved by Federal Highway Administration (FHWA), for construction projects on the National Highway System (NHS) to ensure that materials and workmanship conform to approved plans and specifications (23 CFR sections 637.201, 637.205, 637.207, and 637.209). Recipients are required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate (23 USC 106(e); 23 CFR Part 627). Recipients are required to develop policies and procedures pertaining to the use, accommodation and/or relocation of public and private utility facilities on highway rights-of way using federal highway funds. Recipients are required to develop, maintain, and obtain FHWA approval of their Utility Accommodation Policy (UAP) (23 CFR section 645.215). Condition and Context: Management was unable to provide support documenting the County’s compliance with quality assurance program, value engineering, and utilities special tests for the year ended June 30, 2023. Cause: The County is a pass through entity, and believed the direct recipient of the award was responsible for these special tests requirements. However, there is no formal documentation of this understanding with the direct recipients of these responsibilities. Effect or Potential Effect: The County may not be in compliance with the special tests requirements under Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County formalize its agreement with the pass-through entity to clarify the responsibilities for the special tests requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.