Audit 308200

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-001 Significant deficiency in internal control over compliance with procurement procedures Federal Agency: United States Agency for International Development Program Titles: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Numbers: 7200AA20CA00017, AID-OAA-A-16-00084 Award Periods: 7/27/2020 through 7/26/2025, 09/27/2016 through 09/26/2026 Criteria Procurement standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326, require that a non‐Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. PATH’s procurement policy requires that single source procurements are documented on the contractor justification form and must address the basis on which cost reasonableness was determined. The policy also requires competitive procurements to include documentation of the solicitation documents, proposals, contractor justification form, procurement review and approval form and cost analysis. Condition/Context In our sample of 60 procurement transactions, we identified issues with three specific procurements; Two instances involved the noncompetitive procurement method that did not contain adequate records sufficient to detail the history of procurement in that a contractor justification was missing. Additionally, we identified a competitive procurement under a master service agreement signed in 2015, that did not have the necessary documentation to evidence the initial and subsequent procurement evaluations to ensure PATH continues to receive reasonable value. The total value of these three procurement transactions amounted to $38,922. Cause The Organization’s internal controls over maintaining records sufficient to detail the history of procurement including contractor justification forms was not followed in these instances. Effect Records sufficient to detail the history of procurements were not maintained, thus resulting to noncompliance with the Organization’s procurement policy. Questioned Costs $38,922 Repeat Finding No. Recommendation We recommend the Organization provide training and reminders to the applicable staff involved with these procurements to ensure procurement procedures are followed in future procurements and records are maintained with sufficient detail to evidence the history of procurement including fully completing and retaining the contractor justification form. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Finding 2023-002 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Award Number: 72068522CA00005, AID-OAA-A-16-00084 Award Period: 7/11/2022 through 7/9/2027, 09/27/2016 through 09/26/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee is required to file a FFATA sub‐award report by the end of the month following the month in which the prime recipient awards any sub‐grant in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization had established a process by which to perform FFATA reporting. Among the 13 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Sub-AwardSub-AwardTransactionsSub-AwardReportedAmountMissingTestedNot ReportedNot TimelyIncorrectKey Elements1302N/AN/A Dollar AmountSub-AwardSub-Awardof TestedSub-AwardReportedAmountMissingTransactionsNot ReportedNot TimelyIncorrectKey Elements17,112,678$ -$ 1,061,634$ N/AN/A Cause The late submissions of FFATA reports were attributed to a reporting error that incorrectly excluded close-out awards in 2023. The Organization’s staff identified and corrected this issue with the report’s parameters in January 2024 to prevent future late filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendations We recommend the Organization continue to monitor sub-awards amended during the year and ensure the reporting is made on time. We note that the Organization resolved the issue with the report parameters in January 2024. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.