Audit 356890

Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Criteria – Suspension and debarment (2 CFR 180) Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Cooperative was unable to provide evidence that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Cooperative’s policies and procedures were not adequate to ensure compliance with suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – The Cooperative may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned costs - None Context – The Cooperative was unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Recommendation – We recommend management design and implement internal controls to verify prior to toe entering into covered transaction that potential vendors are not suspension, debarment or otherwise excluded. Management's Response – Management acknowledges the audit finding related to suspension and debarment compliance under the Missouri ARPA Broadband Infrastructure Grant Program. Management is committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 31 CFR 19 subpart C. 1. Established & Implemented Suspension & Debarment Verification Procedures: o All current and new vendors will be verified using the Excluded Parties List System found on Sam.gov. and documentation will be kept in the company’s internal accounting file. This process was implemented in April 2025 and is ongoing. 2. Monitoring: o The Accounting team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.

Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Criteria – Suspension and debarment (2 CFR 180) Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition – The Cooperative was unable to provide evidence that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Cause – The Cooperative’s policies and procedures were not adequate to ensure compliance with suspension and debarment requirements under the Uniform Guidance. Effect or Potential Effect – The Cooperative may enter into covered transactions with vendors who have become suspended, debarred or otherwise excluded. Questioned costs - None Context – The Cooperative was unable to provide evidence covered transactions were not with vendors suspended, debarred or otherwise excluded. Recommendation – We recommend management design and implement internal controls to verify prior to toe entering into covered transaction that potential vendors are not suspension, debarment or otherwise excluded. Management's Response – Management acknowledges the audit finding related to suspension and debarment compliance under the Missouri ARPA Broadband Infrastructure Grant Program. Management is committed to implementing corrective measures to address the identified deficiencies and ensure full compliance with 31 CFR 19 subpart C. 1. Established & Implemented Suspension & Debarment Verification Procedures: o All current and new vendors will be verified using the Excluded Parties List System found on Sam.gov. and documentation will be kept in the company’s internal accounting file. This process was implemented in April 2025 and is ongoing. 2. Monitoring: o The Accounting team conducts annual self-assessments to ensure vendor eligibility documentation is current and up to date. Any vendors that are suspended, debarred, or otherwise excluded from federal assistance programs are reported to the Executive team to ensure compliance. We believe that these actions will significantly mitigate the risks associated with the identified conditions and strengthen our internal control environment and align our procurement practices with federal regulations.