Audit 337011

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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 comply with the 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 (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.