Audit 316813

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Noncompliance Criteria or Specific Requirement – Allowable Costs/Activities: Pursuant to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35, and frequently asked questions addressed by the Treasury, recipients must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the State and Local Fiscal Recovery Funds. Recipients are allowed to use funds to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers and invest in water, sewer and broadband infrastructure. Activities unallowed include those that are an offset as a reduction in net tax revenue, deposits into pension funds, debt service or replenishing financial reserves, satisfaction of settlements and judgments and programs, services or capital expenditures that undermine efforts to stop the spread of COVID-19. Condition: Expenditures were identified in relation to activities allowed or unallowed and allowable costs compliance requirements that were not allowable under the grant. Questioned Costs: Questioned costs totaling $190,000. Context: Out of a population of 73 expenditures, 8 were selected for testing. There was one error identified in testing in which $60,000 was paid for an unallowable settlement payment. Our sample was not intended to be statistically valid. Effect: Nonallowable costs were charged to the grant. Cause: Failure to maintain sufficient review of the allowable costs or activities being charged to the grant. Identification as a Repeat Finding: No Recommendation: We recommend that the County consider reviewing the guidance regarding the allowable costs and activities. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including a thorough review of the compliance requirements. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Noncompliance Criteria or Specific Requirement – Allowable Costs/Activities: Pursuant to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35, and frequently asked questions addressed by the Treasury, recipients must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the State and Local Fiscal Recovery Funds. Recipients are allowed to use funds to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers and invest in water, sewer and broadband infrastructure. Activities unallowed include those that are an offset as a reduction in net tax revenue, deposits into pension funds, debt service or replenishing financial reserves, satisfaction of settlements and judgments and programs, services or capital expenditures that undermine efforts to stop the spread of COVID-19. Condition: Expenditures were identified in relation to activities allowed or unallowed and allowable costs compliance requirements that were not allowable under the grant. Questioned Costs: Questioned costs totaling $190,000. Context: Out of a population of 73 expenditures, 8 were selected for testing. There was one error identified in testing in which $60,000 was paid for an unallowable settlement payment. Our sample was not intended to be statistically valid. Effect: Nonallowable costs were charged to the grant. Cause: Failure to maintain sufficient review of the allowable costs or activities being charged to the grant. Identification as a Repeat Finding: No Recommendation: We recommend that the County consider reviewing the guidance regarding the allowable costs and activities. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including a thorough review of the compliance requirements. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Significant deficiency and noncompliance Criteria or Specific Requirement – Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR § 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, incompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Questioned Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. From a population of three files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support that the subrecipients were being monitored. Cause: Failure to maintain sufficient monitoring of the subrecipient Identification as a Repeat Finding: Yes, 2022-003 Recommendation: We recommend the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication, receipt of the audited financial statements and single audit report, if applicable. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Significant deficiency and noncompliance Criteria or Specific Requirement – Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR § 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, incompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Questioned Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. From a population of three files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support that the subrecipients were being monitored. Cause: Failure to maintain sufficient monitoring of the subrecipient Identification as a Repeat Finding: Yes, 2022-003 Recommendation: We recommend the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication, receipt of the audited financial statements and single audit report, if applicable. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Noncompliance Criteria or Specific Requirement – Allowable Costs/Activities: Pursuant to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35, and frequently asked questions addressed by the Treasury, recipients must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the State and Local Fiscal Recovery Funds. Recipients are allowed to use funds to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers and invest in water, sewer and broadband infrastructure. Activities unallowed include those that are an offset as a reduction in net tax revenue, deposits into pension funds, debt service or replenishing financial reserves, satisfaction of settlements and judgments and programs, services or capital expenditures that undermine efforts to stop the spread of COVID-19. Condition: Expenditures were identified in relation to activities allowed or unallowed and allowable costs compliance requirements that were not allowable under the grant. Questioned Costs: Questioned costs totaling $190,000. Context: Out of a population of 73 expenditures, 8 were selected for testing. There was one error identified in testing in which $60,000 was paid for an unallowable settlement payment. Our sample was not intended to be statistically valid. Effect: Nonallowable costs were charged to the grant. Cause: Failure to maintain sufficient review of the allowable costs or activities being charged to the grant. Identification as a Repeat Finding: No Recommendation: We recommend that the County consider reviewing the guidance regarding the allowable costs and activities. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including a thorough review of the compliance requirements. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Noncompliance Criteria or Specific Requirement – Allowable Costs/Activities: Pursuant to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35, and frequently asked questions addressed by the Treasury, recipients must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the State and Local Fiscal Recovery Funds. Recipients are allowed to use funds to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers and invest in water, sewer and broadband infrastructure. Activities unallowed include those that are an offset as a reduction in net tax revenue, deposits into pension funds, debt service or replenishing financial reserves, satisfaction of settlements and judgments and programs, services or capital expenditures that undermine efforts to stop the spread of COVID-19. Condition: Expenditures were identified in relation to activities allowed or unallowed and allowable costs compliance requirements that were not allowable under the grant. Questioned Costs: Questioned costs totaling $190,000. Context: Out of a population of 73 expenditures, 8 were selected for testing. There was one error identified in testing in which $60,000 was paid for an unallowable settlement payment. Our sample was not intended to be statistically valid. Effect: Nonallowable costs were charged to the grant. Cause: Failure to maintain sufficient review of the allowable costs or activities being charged to the grant. Identification as a Repeat Finding: No Recommendation: We recommend that the County consider reviewing the guidance regarding the allowable costs and activities. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including a thorough review of the compliance requirements. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Significant deficiency and noncompliance Criteria or Specific Requirement – Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR § 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, incompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Questioned Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. From a population of three files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support that the subrecipients were being monitored. Cause: Failure to maintain sufficient monitoring of the subrecipient Identification as a Repeat Finding: Yes, 2022-003 Recommendation: We recommend the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication, receipt of the audited financial statements and single audit report, if applicable. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.

Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Significant deficiency and noncompliance Criteria or Specific Requirement – Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR § 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, incompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Questioned Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. From a population of three files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support that the subrecipients were being monitored. Cause: Failure to maintain sufficient monitoring of the subrecipient Identification as a Repeat Finding: Yes, 2022-003 Recommendation: We recommend the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication, receipt of the audited financial statements and single audit report, if applicable. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.