Audit 306028

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.

Finding 2023-003: Time Tracking and Reporting Information on the Federal Programs: 19.517 and 98.001 Criteria or Specific Requirement: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: I. Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; II. Be incorporated into the official records of the non-Federal entity; III. Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; IV. Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; V. Comply with the established accounting policies and practices of the non-Federal entity; VI. [Reserved] VII. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. VIII.Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.”Condition: During our testwork, we determined that CVT did not adequately document employee time spent on each Federal program when multiple Federal programs were in process in one location. Cause: Federal awards that are run concurrently within the same location are generally for the same over-all program objective. Employees are not able to consistently record time spent on each particular Federal award within their timesheets. As a result, allocations of time made in the general ledger do not always reflect what is recorded on the timesheet. Effect or Potential Effect: CVT could inadvertently charge time to the Federal award that was not truly spent working on the Federal award. This could result in the Federal Government over-paying for salaries associated with the award. Questioned Costs: None noted. Context: We noted that employees selected for testing did not always have completed and detailed timesheets outlining hours spent working on various awards that are run in the same location. Additionally, we noted instances in which completed timesheets did not agree to final allocation in the accounting system. Identification as a Repeat Finding: 2022-002 and 2022-003 Recommendation: We recommend that management should develop appropriate documentation to support when an employee charges a program that is funded by various donors. A consistent and reasonably methodology which may be based on awards budgets should be the basis of the ending allocation.