Audit 310723

Item 2023‐002 Written policies, procedures, and standards of conduct COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027 U.S. Department of Treasury Grant period: Year ended September 30, 2023 Questioned Costs – $0 Condition – The City does not have all of the written policies, procedures and standards of conduct required by UG. Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐ Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following:  § 200.302 Financial management  § 200.305 Payment § 200.319 Competition  § 200.320 Methods of procurement to be followed  § 200.430 Compensation—personal services  § 200.431 Compensation—fringe benefits Cause of Condition – The City has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the City implement the required written policies and procedures. Management’s Response – Management agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.

Item 2023‐003 Performance Reporting – Annual Project and Expenditure Report Coronavirus State and Local Fiscal Recovery Fund ALN# 21.027 U.S. Department of Treasury Grant period – Year ended September 30, 2023 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have controls in place to ensure that required reporting requirements under the compliance supplement are satisfied. 2 CFR 200.328 requires the City to file the Annual Project and Expenditure Report under the Performance Reporting requirement of the grant. Condition – Adequate controls were not in place to ensure that annual reporting was filed in accordance with performance reporting requirements. Cause – Changes in leadership roles at the grantee led to a lack of sufficient controls over the communication of the reporting requirement to ensure the accuracy and completeness of performance reporting under the grant. Effect – Lack of notification of the reporting requirement could lead to disallowed costs. We noted that the annual report was subsequently submitted to the grantor. However, our audit disclosed no instances of unallowable costs. Questioned Costs – Not determinable. Recommendation – We recommend the strengthening of controls to ensure annual reporting required under the compliance supplement is performed in a timely manner. Management’s Response – The City will strengthen the controls in place to provide assurance that annual reporting is performed timely in accordance with program guidelines.

Item 2023‐002 Written policies, procedures, and standards of conduct COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027 U.S. Department of Treasury Grant period: Year ended September 30, 2023 Questioned Costs – $0 Condition – The City does not have all of the written policies, procedures and standards of conduct required by UG. Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐ Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following:  § 200.302 Financial management  § 200.305 Payment § 200.319 Competition  § 200.320 Methods of procurement to be followed  § 200.430 Compensation—personal services  § 200.431 Compensation—fringe benefits Cause of Condition – The City has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the City implement the required written policies and procedures. Management’s Response – Management agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.

Item 2023‐003 Performance Reporting – Annual Project and Expenditure Report Coronavirus State and Local Fiscal Recovery Fund ALN# 21.027 U.S. Department of Treasury Grant period – Year ended September 30, 2023 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have controls in place to ensure that required reporting requirements under the compliance supplement are satisfied. 2 CFR 200.328 requires the City to file the Annual Project and Expenditure Report under the Performance Reporting requirement of the grant. Condition – Adequate controls were not in place to ensure that annual reporting was filed in accordance with performance reporting requirements. Cause – Changes in leadership roles at the grantee led to a lack of sufficient controls over the communication of the reporting requirement to ensure the accuracy and completeness of performance reporting under the grant. Effect – Lack of notification of the reporting requirement could lead to disallowed costs. We noted that the annual report was subsequently submitted to the grantor. However, our audit disclosed no instances of unallowable costs. Questioned Costs – Not determinable. Recommendation – We recommend the strengthening of controls to ensure annual reporting required under the compliance supplement is performed in a timely manner. Management’s Response – The City will strengthen the controls in place to provide assurance that annual reporting is performed timely in accordance with program guidelines.