Audit 377089

Significant deficiency in internal control over compliance related to reporting. Federal Agency: United States Department of Commerce Program Title: Congressionally Identified Awards and Projects Assistance Listing Number: 11.469 Project Number: NA25NMFX469G0061 Award Period: November 1, 2023 - October 31, 2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act) that are codified in 2 Code of Federal Regulations (CFR) Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register the covered subawards in the System for Award Management (SAM) and report the required subaward data no later than the last day of the month following the month the subaward was made. Condition/Context for Evaluation During the award period ended June 30, 2025, Washington Maritime Blue did not report a covered subaward as required by the Transparency Act. Transaction Tested: 1 Dollar Amount of Transactions Tested: $10,953 Subaward Not Reported: 1 Subaward Not Reported: $49,646 Report Not Timely: 1 Report Not Timely: $10,953 Subaward Amount Incorrect: NA Subaward Amount Incorrect: NA Subaward Missing Key Elements: 1 Subaward Missing Key Elements: $49,646 Effect or Potential Effect The Organization did not comply with the subaward reporting requirements as specified in 2 CFR 170. Questioned Costs Not applicable. Cause Though the Organization has established internal controls for submitting covered subawards as required by the Transparency Act, the Organization made an incorrect determination that the covered subaward was under the required reporting limit. Repeat Finding No Recommendation We recommend that the Organization ensure required reporting of covered subawards is made in accordance with the Transparency Act. Views of Responsible Officials Management agrees that the required FSRS report was not made. After the issue was raised as part of the Single Audit, management took measures to enter the required subawards.

Significant deficiency in internal control over compliance related to suspension and debarment. Federal Agency: United States Department of Commerce Program Title: Build to Scale Assistance Listing Number: 11.024 Project Number: ED23OIE0G0139 Award Period: January 1, 2025 - September 30, 2025 Criteria The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition/Context for Evaluation During the award period ended June 30, 2025, the Organization did not perform suspension and debarment requirements for the three out of three covered transactions tested as part of this audit. Effect or Potential Effect The Organization did not fully comply with the suspension and debarment requirements regarding covered transactions. Questioned Costs Not applicable. Cause Though the Organization has established internal controls for suspension and debarment, the Organization made an incorrect determination that the suspension and debarment requirements outlined in 2 CFR 200 Part 180 only applied to subawards. Repeat Finding No Recommendation We recommend that the Organization ensure suspension and debarment procedures are incorporated into their procurement policy. Views of Responsible Officials Management concurs with the finding and has provided the accompanying management corrective action plan.