Findings Citing § 200.214

Procurement Suspension and Debarment (EPA Clean Water State Revolving Fund Assistance Listing 66.458) Condition: The Corporation did not perform verification of vendors against the System for Award Management (SAM.gov) to ensure vendors were not suspended or debarred prior to the award of contracts or payments for services. Criteria: In accordance with 2 CFR 200.214 and 2 CFR 200.318, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities are required to verify that vendors are not suspended or debarred, which may be accomplished through review of SAM.gov or by obtaining appropriate certifications from vendors. Effect: The Corporation is at risk of contracting with or making payments to vendors that are suspended or debarred, which could result in noncompliance with federal requirements and potential disallowance of costs. Questioned Costs: None Noted. Recommendation: We recommend that the Corporation implement procedures to verify vendor eligibility prior to awarding contracts or making payments using SAM.gov or by obtaining appropriate certifications from vendors. Documentation of this verification should be retained. Views of Responsible Officials: Management agrees with the finding and will implement procedures to verify vendor eligibility through SAM.gov or equivalent methods for applicable vendors.

Finding 2025-001 Procurement, Suspension, and Debarment Highway Planning and Construction – 20.205 Criteria: Pursuant to 2 CFR § 200.214, the entity must verify that potential vendors are not excluded or disqualified before forming a contract regarding a covered transaction in accordance with the Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: As a result of our testing of Procurement, Suspension, and Debarment, we noted that the Commission did not have sufficient audit evidence to demonstrate the suspension and debarment of the vendors were reviewed prior to a contract for two of the contracts selected. Cause: Due to staff oversight, the vendors were not evaluated for suspension or debarment. Effect: The Commission is not in compliance with the Procurement, Suspension, and Debarment requirements and internal controls are not functioning as designed. Questioned Costs: The amount of questioned costs, if any, is indeterminable. Recommendation: The Commission should review policies in place over Procurement, Suspension, and Debarment and establish procedures to identify clear roles for the review of vendors prior to a contract. Management’s Response: Information provided in the Master Agreement with PennDOT to perform the suspension and debarment review did not function and TCRPC staff was not permitted access to the database to perform the required review. Guidance provided during the audit indicated the suspension and debarment status also can be accessed through SAM.gov, for which TCRPC staff does have access. SAM.gov, or other accessible database, will be used by the Executive Director, or Associate Director or Administrative Coordinator as assigned, in future suspension and debarment reviews prior to contracting with vendors.

Finding: Item 2025-001 – Suspension and Debarment Significant Deficiency Federal Program – CDFI Equitable Recovery Program (CDFI ERP) AL Number – 21.033 Federal Award Numbers – 22ERP061009 Federal Agency – U.S. Department of Treasury Criteria: The CDFI ERP Assistance Agreement Section 5.10(d) requires the Recipient to determine whether any individual or entity receiving any portion of the CDFI ERP Award is currently debarred, suspended, excluded, or disqualified by the U.S. Department of the Treasury or any other Federal department or agency, as described in 31 C.F.R. Part 19. The Agreement further requires the Recipient to include in all procurement and nonprocurement contracts and agreements, between the Recipient and any individual or entity receiving any portion of the CDFI ERP Award, a representation that such individual or entity is not currently debarred, suspended, excluded, or disqualified by any Federal department or agency. Additionally, 2 CFR 200.214 requires non Federal entities to comply with suspension and debarment requirements and to ensure that covered transactions are not awarded to parties listed on the System for Award Management (SAM.gov) exclusion list. Condition/context: The Recipient did not include the required suspension and debarment representation in the loan agreement, promissory note, or other supporting documentation for the CDFI ERP funded loan. Further, the Recipient did not perform or document a verification in SAM.gov to verify that the loan recipient was not suspended, debarred, or otherwise excluded from participation in Federal programs. Cause: The Recipient did not have adequate internal controls or written procedures to ensure that suspension and debarment verifications were performed and that required representations were incorporated into CDFI ERP funded agreements. Effect: Without obtaining the required representations or verifying eligibility through SAM.gov, the Recipient increases the risk of providing Federal funds to an entity that is suspended, debarred, or otherwise excluded from Federal programs. This exposes the Recipient to potential noncompliance with Federal regulations and may result in questioned costs or other corrective actions by the awarding agency. Questioned cost: Not applicable. Repeat finding: Not applicable. Recommendation: The Recipient should update its policies and procedures to ensure compliance with CDFI ERP Assistance Agreement Section 5.10(d) and 2 CFR 200.214, including: • Performing and documenting suspension and debarment checks in SAM.gov prior to executing any agreement funded with CDFI ERP Award funds. • Incorporating the required suspension and debarment representation into all procurement and nonprocurement contracts, including loan agreements and promissory notes. The Recipient should perform a retrospective review of CDFI ERP funded transactions to determine whether additional corrective actions are necessary. View of responsible officials: Management's response is reported in "Corrective Action Plan" at the end of this report.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Project Funding (CPF) Program Assistance Listing Number: 14.251 Federal Award Identification Number and Year: B-22-CP-MN-0492, 2025 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: The non‑federal entity is required to have controls in place to ensure compliance with suspension and debarment requirements. Uniform Guidance (2 CFR §200.214) requires non‑federal entities to verify that contractors are not suspended or debarred from participating in federal programs. Verification may be accomplished by reviewing the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), obtaining a certification from the contractor, or by including a clause or condition in the covered transaction. Condition: The City did not maintain documentation demonstrating that required suspension and debarment verifications were performed for contractors associated with the Community Project Funding program. Questioned costs: None. Context: During testing of compliance with suspension and debarment requirements for the Community Project Funding program, the auditors reviewed covered transactions subject to suspension and debarment requirements. Documentation evidencing verification through SAM.gov or other allowable methods was not retained for the transactions tested. Cause: The City does not have a formalized policy or documented procedures requiring suspension and debarment verification to be performed and retained for covered transactions associated with federal programs. Effect: Failure to perform and document required suspension and debarment procedures could result in the City entering into transactions with entities that are suspended or debarred, resulting in potential noncompliance with federal requirements. Repeat Finding: No. Recommendation: We recommend the City formalize suspension and debarment compliance procedures in a written policy and ensure verification is performed and documented for all covered transactions prior to entering into contracts funded by Community Project Funding. Views of responsible officials: There is no disagreement with the audit finding. Management acknowledges the need to formalize suspension and debarment procedures and will implement controls to ensure required verifications are performed and documented for applicable transactions.

SIGNIFICANT DEFICIENCY 2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Federal Agency: Department of Health and Human Services Federal Program or Cluster: Grants for Capital Development in Health Centers Assistance Listing Number: 93.526 Federal Award Numbers and Years Award Period: 9/15/21-8/31/25 - 4 C8ECS44755-01-07 Questioned Costs $0 Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. documentation of verification through SAM.gov or equivalent methods could not be provided by management. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors used on the project funded with federal awards. Criteria: In accordance with 2 CFR 200.214, nonfederal entities are subject to procurement, debarment and suspension regulations. The regulations in 2 CFR part 180 restrict awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Cause: The Organization did not follow its internal policy for procurement, suspension and debarment. Effect: Failure to verify vendor eligibility increases the risk of awarding federal funds to ineligible parties, which may result in questioned costs and potential disallowance of expenditures by a federal awarding agency. Recommendation: We recommend the Organization ensure the staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already established policies that the Organization has regarding such requirements. Identification of repeat findings: This is not a repeat finding. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Organization has reviewed and updated the Organization's procurement policy in May 2025 and has trained staff as necessary to ensure staff adhere to the policy prospectively.

Reference Number: 2024-001 Program Name: 14.267 Continuum of Care Reference Number: 2025-001 Program Name: 14.267 Continuum of Care Description: Procurement Criteria: 2 CFR 180.300 and 2 CFR 200.214 prohibit nonfederal entities from contracting with parties that are suspended or debarred. For covered transactions equal to or exceeding $25,000, the Organization must verify that the vendor is not excluded by checking the System for Award Management (SAM.gov) or through other approved methods. Additionally, HUD procurement requirements under 2 CFR 200.318 require entities to ensure vendor eligibility. When multiple transactions with the same vendor exceed $25,000 in aggregate, the total amount should be considered in determining whether suspension or debarment requirements apply. Condition: The Organization entered into multiple rental agreements with the same rental companies. While each contract was less than $25,000, total payments to the rental companies exceeded $25,000. The Organization did not perform or document a suspension and debarment verification. Questioned Costs: None identified. Cause: The Organization did not follow their procurement policy. The Organization’s procurement policy states that “no contract shall be made to the parties listed on the General Services List of Parties Excluded from Federal Procurement or Non-procurement Programs in accordance with E.O.’s 12549 and 12689”. Effect: The Organization is not in compliance with federal and HUD procurement requirements and may have contracted with a suspended or debarred party. This increases the risk of questioned costs. Identification of a Repeat Finding: This is not repeat finding. Auditors’ Recommendation: We recommend the Organization implement procedures to ensure SAM.gov verification is performed annually on all covered transactions and prior to signing leases with new rental companies. Views of Responsible Officials: See attachment for the Organization’s corrective action plan.

2025-001: Lack of Documentation of Suspension/Debarment Testing at Time of Procurement Federal Department: Department of Housing and Urban Development Assistance Listing #: 14.251 Internal Controls Significant Deficiency & Noncompliance Category of Finding – Procurement, Suspension, and Debarment Criteria - In accordance with 2 CFR 200.214 and 2 CFR part 180, recipients of federal funds must not enter into covered transactions with parties that are suspended or debarred. The Uniform Guidance requires that entities verify the exclusion status of vendors or subrecipients by checking the System for Award Management (SAM) Exclusions list (https://sam.gov) prior to entering into a covered transaction and keeping documentation of checking SAM before entering into those contracts. Condition - The Organization has a written policy requiring verification that vendors involved in covered procurement transactions under this program are not suspended or debarred. For the period under audit, program management represented that suspension and debarment checks were performed prior to entering into agreements with vendors subject to this requirement; however, the Organization did not retain documentation evidence that these checks were performed. Context: During the audit, we performed SAM Exclusions checks over all vendors over $25,000 paid under this grant, and no vendors were identified as suspended, debarred, or otherwise excluded. However, documents of the testing performed by the Organization were not properly kept. Cause - Management indicated that while the required checks were performed by the program manager, there was not a formal process to ensure that documentation of the completed SAM checks (such as dated screenshots, printouts, or other electronic evidence) was retained in the procurement or grant files. Effect - Because documentation of the suspension and debarment checks was not retained, the Organization is unable to demonstrate, based solely on its records, that it consistently complied with the suspension and debarment requirements for covered transactions during the period under audit. This represents a weakness in internal control over compliance and results in noncompliance with the documentation expectations for this compliance requirement. Recommendation - We recommend that the Organization strengthen its internal controls over documentation procurement and suspension and debarment for federal programs by: Implementing a monitoring or review control (such as periodic file reviews) to verify that required documentation is consistently maintained. CLARE HOUSING SCHEDULE OF FINDINGS AND QUESTIONED COSTS For the Year Ended December 31, 2025 Auditee’s comments and response – Clare Housing will continue to conduct verifications which are consistent with the organization’s financial policies by validating the potential vendors’ status in the System for Award Management (www.SAM.gov) portal and document the verification with a screenshot of the validation before any payment to a vendor is completed. Clare Housing will also establish a centralized electronic filing system that houses the documentation for suspension/debarment verification, and will track and report any findings to management, including corrective actions for any recurring deficiencies. Responsible party for corrective action: Zach Petroski, Director of Finance Repeat Finding: No

Finding Number: 2025 002 Finding Type: Significant deficiency in internal controls over compliance related to Procurement, Suspension and Debarment Information on the Federal Program: Program Name: Congressional Directives (93.493) Federal Awards Project Title: Community Project Funding/Congressionally Directed Spending ‐ Construction Award Period: June 1, 2023 – September 29, 2026 Award Number: CE2CS49443 and CE2CS52630 Agencies: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Criteria: Under 2 CFR § 200.214 (Suspension and Debarment), non-Federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in Federal programs. To comply with these requirements, entities must implement internal controls reasonably designed to ensure that Federal awards are not used to pay or engage suspended or debarred individuals or entities, including appropriate verification procedures such as screening against the SAM.gov Exclusions List. Condition: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all contractors. SAM.gov checks were performed only for employees, rather than being performed for all applicable vendors whose yearly expenditures charged to the grant met or exceeded $25,000. As a result, the Organization’s exclusion screening process was not consistently applied to all vendors who met the expenditure threshold. Cause: The Organization's policies and procedures did not establish a comprehensive process to identify contractors and vendors subject to Federal suspension and debarment requirements and ensure that SAM.gov exclusion screenings were performed and documented. Staff turnover and operational challenges contributed to the breakdown in the control process. Effect: Without appropriately designed and consistently applied exclusion screening procedures, there is an increased risk that Federal funds could be used to compensate suspended or debarred entities. This could result in noncompliance with Federal award requirements and may result in questioned costs or other Federal award consequences if such entities were engaged. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that the Organization strengthen its internal controls over compliance with suspension and debarment requirements by implementing formal policies and procedures to ensure SAM.gov exclusion screenings are performed and documented for all applicable contractors and vendors subject to Federal suspension and debarment requirements. At a minimum, the Organization should: • Perform SAM.gov exclusion checks at the time of engagement for all contractors whose expenditures could be charged to Federal awards; • Establish a defined frequency for ongoing monitoring (e.g., periodic or at least annually) to ensure continued compliance; and • Document the results of all exclusion searches and maintain evidence to support compliance with Federal requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Management will implement the recommendations above.

Environmental Protection Agency Direct Program: Congressionally Mandated Projects - 66.202 Award Year: 2023 Criteria or Specific Requirement - Suspension and Debarment In accordance with 2 CFR 200.214, 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. In accordance with 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for a vendor prior to entering into a contract. Cause: The BPU's controls to ensure suspension and debarment checks on vendors receiving federal funds did not operate effectively. Effect or Potential Effect: Federal funds could be paid to entities that are suspended or debarred. Questioned Costs - None Context: The BPU entered into a contract during the year ended December 31, 2025 that was considered a "covered transaction" and spent approximately $74,000 under this contract. This contract was selected for testing suspension and debarment and the BPU did not check the vendor's suspension and debarment status. Identification of Prior Year Finding: N/A Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with federal funds. Views of Responsible Official and Planned Corrective Action: Management agrees with finding. See corrective action plan.

Subject: 2025-002 Material Weakness and Noncompliance – Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness and Noncompliance – Procurement and Suspension and Debarment Criteria: In accordance with 2 CFR §200.214 and 2 CFR Part 180, the City is required to ensure that it does not enter into a covered transaction with a party that is suspended or debarred. Verification must be performed through one of the following: checking SAM.gov, collecting a certification, or adding a contract clause requiring compliance. Condition and Context: The City has a formalized procedure for verifying suspension and debarment status for covered transactions under the revenue loss category for the CSLFRF award but the verification process did not occur prior to payment of new vendors during 2025. All vendors paid through June 2025 were verified on June 26, 2025 and all vendors paid through December 31, 2025 were verified on January 26, 2026. Without advance verification, the City risks using federal funds to engage with ineligible vendors, which could result in questioned costs, repayment obligations to the federal government, or future audit findings that may impact continued federal funding. Cause and Effect: The City did not complete suspension and debarment verification prior to payment for each of the ten covered transactions tested, resulting in a material weakness of internal control over compliance and noncompliance with respect to the suspension and debarment requirements of the CSLFRF program and increased risk of using federal funds with ineligible vendors. This is a repeat finding of 2024-002. Recommendation: We recommend the City ensure suspension and debarment checks are performed on all CSLFRF transactions prior to payment to new vendors and documented appropriately. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation and plans to implement a corrective action plan by December 31, 2026. City staff are in the process of updating internal policies to ensure the suspension and debarment checks are performed on all CSLFRF transactions prior to payment to vendors and documented appropriately.

Assistance Listing Number, Federal Agency, and Program Name - 10.727, U.S. Department of Agriculture, Inflation Reduction Act Urban & Community Forestry Program Federal Award Identification Number and Year - 24 DG 11094200 194, 2024; 24 CA 11132544 013, 2024 Pass through Entity - U.S. Department of Agriculture (Direct Funded); GreenLatinos Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align 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 - Management did not have controls in place to ensure documentation evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity was maintained. Questioned Costs - N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - While gaining an understanding of Openlands' internal controls, we noted management was unable to provide documentation to support that checks for suspension and debarment occurred before the organization entered into a covered transaction. We were able to verify in our sample testing that management did not enter into contracts with individuals or organizations suspended or debarred from participating in federal programs. Cause and Effect - A lack of controls could result in material noncompliance with federal procurement standards. Recommendation - We recommend management retain documented evidence that checks for suspension and debarment that have occurred before entering into a covered transaction with outside contractors. Views of Responsible Officials and Corrective Action Plan - Management concurs with the finding. We acknowledge that, for the awards issued under the Inflation Reduction Act Urban and Community Forestry Program (Assistance Listing Number 10.727), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained by the responsible department. This represents a documentation lapse rather than a deficiency in internal controls, as Openlands routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micropurchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $15,000. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected and is currently in the process of executing an update to internal control policies to ensure these checks are maintained prior to entering into a contract by the responsible department, as well as updating a clause to all standard vendor contracts requiring a self-certification that they are not excluded, debarred, or suspended from entering into covered transactions with the federal government.

2025-001: PROCUREMENT (repeat comment) Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Contracts for FY 2025 were the same contracts for FY 2024 for this program. Therefore, this finding is a carryover of the FY 2024 finding. Cause/Effect: Management oversight. Questioned Cost: None Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.

2025-003: PROCUREMENT - SUSPENSION AND DEBARMENT Type: Considered a significant deficiency in internal control over compliance Program: ALN 93.696 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Cause/Effect: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.

2025-001: Lack of Documentation of Suspension/Debarment Testing at Time of Procurement Federal Department: Department of the Treasury Assistance Listing #: 21.027 Internal Controls Material Weakness & Noncompliance Category of Finding – Procurement, Suspension, and Debarment Criteria - In accordance with 2 CFR 200.214 and 2 CFR part 180, recipients of federal funds must not enter into covered transactions with parties that are suspended or debarred. The Uniform Guidance requires that entities verify the exclusion status of vendors or subrecipients by either (1) checking the System for Award Management (SAM) Exclusions list (https://sam.gov) prior to entering into a covered transaction, (2) Obtaining certifications from vendors or subrecipients that they are not suspended or debarred, if permitted under 2 CFR part 180, or (3) including appropriate suspension/debarment language in contracts and subawards to reflect responsibility not to award to excluded parties; and keeping documentation of this testing being performed before entering into those contracts. Condition - The Organization has a written policy requiring verification that vendors involved in covered procurement transactions under this program are not suspended or debarred, typically by including the required language in the contracts. For the project tested during the audit, management represented that suspension and debarment were performed prior to entering into agreements with vendors subject to this requirement as required. Context: The audit identified two vendors that were funded using these funds during the project and determined that neither contract included the suspension and disbarment language expected. During the audit, the auditor determined that the vendors were not listed as suspended or disbarred on sam.gov. Cause - The Organization typically includes the required suspension and debarment language in their contracts which are based on a template. Due to the ARPA and other unique funding sources of this project, the template contract was not used, and the suspension and debarment language was accidently not included in the alternative contract used. Effect – The Organization was noncompliance with the suspension and debarment requirement under Uniform Guidance. Though these specific vendors were not suspended and debarred, failing to test suspension and debarment prior to entering into contracts could lead to potentially contracting with disallowed vendors which could result in losing federal funding or being required to return funds Recommendation - We recommend that the Organization strengthen its internal controls over contracts as it relates to including the required suspension and debarment language. If that is not possible, we recommend the Organization institute alternative suspension and debarment testing procedures to ensure that all required vendors are tested prior to entering into a contract with a vendor. Auditee’s comments and response - Management plans to ensure, with all contracts, that the vendors sign a statement, either included in the contract or as a rider to the contract which confirms that they are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by a federal department or agency. Responsible party for corrective action: Nancy Cashman, Executive Director Repeat Finding: No

Finding No.: 2025-001 Federal Agency: U.S. Department of Interior AL Program: Economic, Social, and Political Development of the Territories Award No.: D22AP00317 and D20AP00137 Area: Procurement, Suspension and Debarment Questioned Cost: $333,198 Criteria: 2 CFR § 200.214 requires non-federal entities to ensure that vendors are not suspended or debarred from participating in federal programs. This verification must be performed by:  Checking the System for Award Management (SAM) Exclusions list,  Obtaining a certification from the vendor, or  Including a clause or condition in the transaction that the vendor is not suspended or debarred. Condition: During testing of 8 procurement transactions, we noted that GWA did not perform or document suspension and debarment verification for 2 vendors. The total disbursements associated with these vendors amounted to $333,198. Cause: GWA did not consistently implement procedures or controls to ensure that suspension and debarment checks are performed and documented for all applicable vendors. Effect or Potential Effect: Failure to perform and document suspension and debarment verification increases the risk that GWA may contract with vendors that are ineligible to receive federal funds, resulting in noncompliance with federal regulations and potential questioned costs. Recommendation: We recommend that GWA strengthen its procurement controls by implementing and enforcing procedures to ensure that suspension and debarment verification is performed and properly documented for all applicable vendors prior to contract award. This may include requiring SAM checks, maintaining evidence of verification, and providing periodic training to procurement personnel. Identification as a Repeat Finding: Not applicable. Views of Responsible Officials: GWA acknowledges inconsistent implementation of procedures that required suspension and debarment verifications for 2 of the 8 procurement transactions tested and concurs with the recommendation to strengthen its procurement controls to address this finding. During FY2025, GWA implemented corrective actions including an immediate directive issued in April 2025 to comply with updated procurement procedures formally approved in September 2025. These procedures included standardized checklists, required vendor certification forms and mandatory SAM.gov verification procedures for all federally funded procurements. Training was conducted to required personnel in October 2025 and subsequently expanded to a broader audience in December 2025. All related SOPs and guidance materials were also made available through the employee intranet. Management also directed staff to retrospectively perform and document SAM.gov verifications for certain procurements initiated prior to implementation of the revised procedures. However, due to procurement management and personnel transitions, the retrospective review was not fully completed for the sampled procurements. Subsequent checks confirmed that the vendors were not suspended or debarred. GWA will continue reinforcing monitoring procedures to ensure all required compliance documentation is timely completed and retained in the procurement files.

2025-001 Procurement, Suspension and Debarment – Significant Deficiency in Internal Control over Compliance Identification of federal programs: 20.205 Highway Planning and Construction Grand award numbers: 693JJ22440000Y176AK307502400199900 693JJ22440000Y602AK307502400199900 693JJ22540000Y177AK307502500299900 693JJ22540000Y271AK307502500199900 693JJ22540000Y602AK307502500199900 Criteria: Per 2 CFR §200.318(i), non-Federal entities must maintain records sufficient to detail the history of procurement transactions, including the rationale for the method of procurement, contractor selection, and the basis for contract price. Additionally, 2 CFR §200.214 prohibits awards, subawards, and contracts with parties that are suspended or debarred, requiring entities to verify contractor eligibility prior to award. Effective internal controls over procurement activities should ensure required documentation is obtained, reviewed, and retained in procurement files. Condition: During testing of procurement transactions, we noted three instances in which adequate supporting documentation was not retained internally to support that the vendors were not suspended or debarred. We also noted one sole source procurement transaction in which documentation supporting the noncompetitive procurement justification and approval was not maintained at the time of purchase. Cause: Management indicated procurement documentation procedures were not consistently followed, and existing review controls did not detect the missing documentation prior to purchase approval and payment processing. Effect or potential effect: Failure to maintain required procurement documentation increases the risk of noncompliance with federal procurement requirements and may result in unsupported procurement actions or questioned costs. Questioned Costs: None. Identification of Repeat Finding: N/A Recommendation: We recommend management strengthen internal controls over procurement activities by implementing procedures to ensure sole source procurements are properly supported with written justification and suspension and debarment checks are performed and documented timely. Views of Responsible Officials: Management concurs with this finding. See corrective action plan below.

Finding Type: Significant deficiency in internal controls over compliance related to Procurement, Suspension and Debarment Information on the Federal Program: Program Name: Health Center Program Cluster (93.224/93.527) Federal Awards Project Title: Health Center Program Award Period: February 1, 2024 – January 31, 2025 and February 1, 2025 – January 31, 2026 Award Number: H80CS26642 Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Criteria: Under 2 CFR § 200.214 (Suspension and Debarment), non-Federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in Federal programs. To comply with these requirements, entities must implement internal controls reasonably designed to ensure that Federal awards are not used to pay or engage suspended or debarred individuals or entities, including appropriate verification procedures such as screening against the SAM.gov Exclusions List. Condition: The Organization did not have adequately designed internal controls to ensure compliance with Federal suspension and debarment requirements. Specifically, the Organization did not perform SAM.gov exclusion screenings for all employees and contractors. SAM.gov checks were performed only for certain clinical providers and were aligned with the Organization’s credentialing cycle (approximately every two years), rather than being performed for all applicable individuals upon hire and/or on a recurring basis. As a result, the Organization’s exclusion screening process was not consistently applied to all individuals whose compensation is charged, in whole or in part, to Federal awards. Cause: The condition resulted from a lack of full understanding of Federal suspension and debarment requirements and the expectation for entity-wide exclusion screening controls under the Uniform Guidance. As a result, the Organization’s policies and procedures did not establish a comprehensive process to ensure SAM.gov exclusion verification was performed for all applicable employees and contractors. Effect: Without appropriately designed and consistently applied exclusion screening procedures, there is an increased risk that Federal funds could be used to compensate suspended or debarred individuals or entities. This could result in noncompliance with Federal award requirements and may result in questioned costs or other Federal award consequences if such individuals or entities were engaged. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that the Organization strengthen its internal controls over compliance with suspension and debarment requirements by implementing formal policies and procedures to help ensure SAM.gov exclusion screenings are performed for all applicable employees and contractors. At a minimum, the Organization should: • Perform SAM.gov exclusion checks at the time of hire or engagement for all employees and contractors whose compensation could possibly be charged to Federal awards; • Establish a defined frequency for ongoing monitoring (e.g., periodic or at least annually) to ensure continued compliance; • Document the results of all exclusion searches and maintain evidence to support compliance with Federal requirements. Additionally, we recommend the Organization evaluate its broader exclusion screening processes to ensure alignment with Federal health care program integrity requirements, including screening against the Office of Inspector General’s List of Excluded Individuals and Entities (LEIE), to further strengthen compliance controls. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. Management will implement procedures to ensure SAM.gov exclusion screening is performed for all employees and contractors whose compensation is charged to Federal awards and will strengthen internal controls to support compliance with 2 CFR § 200.214. Management will also evaluate and enhance procedures to incorporate routine screening against the OIG List of Excluded Individuals and Entities (LEIE) as part of its overall compliance process.

Finding 2025-001- Material Weakness related to Procurement and Suspension and Debarment Identification of the Federal Program Federal Agency: Department of Health and Human Services, Department of Homeland Security, Department of Defense, Department of Justice, National Science Foundation, Department of Agriculture, US Agency for International Development Program Name: Research and Development Cluster Assistance Listing Number: Various Criteria or Specific Requirement: 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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 be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR Section 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The Medical Center did not evaluate all vendors for suspension and debarment during the fiscal year. As a result, there were instances of procurement transactions where the vendor was not subjected to suspension and debarment evaluation procedures prior to entering into the transaction. Cause: The issue occurred due to deficiencies in the design and operation of controls over the completeness and accuracy of vendor information provided to the third-party service provider for suspension and debarment monitoring. Specifically, controls were not in place to ensure that all vendors used for the Research and Development Cluster program expenditures were included in the vendor listing submitted for suspension and debarment monitoring. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance with applicable requirements. Accordingly, the Medical Center could have entered into a procurement transaction with a suspended or debarred vendor. Questioned Costs: No questioned costs were identified. Context: Management was unable to provide evidence of a control being consistently performed throughout the audit period. The total population consisted of 1,374 vendors utilized for expenditures charged to the Research and Development Cluster. Our testing identified that 844 vendors, representing approximately $80 million in expenditures, were not evaluated for suspension and debarment prior to entering into a transaction. The remaining 530 vendors were appropriately evaluated. Subsequently, all 1,374 vendors were evaluated for suspension and debarment and none were noted as being suspended or debarred. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Management should design and implement effective internal controls to ensure the completeness and accuracy of vendor listings submitted for suspension and debarment evaluation. Controls should include procedures to verify that all vendors associated with Federal program expenditures are evaluated prior to entering into transactions and that evaluation results are appropriately documented and monitored on an ongoing basis. Views of Responsible Officials: Management concurs with the finding and has implemented procedures to ensure the vendor list for suspension and debarment evaluation is complete and accurate.

Department of Treasury, State of Indiana Office of Community and Rural Affairs, Federal Financial Assistance Listing 21.029, AL192-23-NLC-23-103, AL192-23-NLC-25-104 A, AL192-23-NLC-25-104 B Coronavirus Capital Projects Fund Procurement, Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards to Uniform Guidance standards in sections 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are applicable. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contract with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: Testing of the federal program identified the following: • The Entity’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance • Four instances where the Entity did not follow the procurement process and did not have any formal documentation in place with the vendors. • Four instances where the Entity entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Cause: The Entity was not aware of the federal procurement requirements. Contract provisions were not evaluated compared to Uniform Guidance contract requirements. Contracts entered were not evaluated in accordance with Uniform Guidance as it relates to suspension and debarment. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Entity would be noncompliant with the compliance requirements outlined above. Additionally, the Entity may enter into a covered transaction with a vendor that is suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 4 out of 10 vendors were selected for testing. Repeat Finding form Prior Year: No Recommendation: We recommend the Entity update their procurement policy to ensure it includes all the required elements in accordance with Uniform Guidance. In addition, we suggest that management implement procedures and control processes related to the review of procurement to ensure the procurement methods are being followed and documentation is retained to support compliance. Also, management should ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into a procurement transaction. Views of Responsible Officials: Management agrees with the finding.

2025-001 – Suspension and Debarment Finding Type: Significant Deficiency in Internal Control over Compliance/Noncompliance Program: ALN 14.267 – Supportive Housing Program • Grant number MI0265L5F182316 • Grant number MI0265L5F182417 Criteria: As required by 2 CFR 200.214, Non-Federal entities are subject to the debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The vendor used for this grant was not checked for suspension and debarment prior to execution of the contract. Also, the contract did not include certification that the vendor was not suspended or debarred. Cause: Management oversight. Questioned Cost: None. Recommendation: We recommend that the CMHSP either document the check for suspension and debarment prior to execution of the contract or update contract language to include certification that vendor is not suspended or debarred. View of Responsible Official: Management is in agreement with this recommendation

Criteria or Specific Requirements: In accordance with 2 CFR Part 180 and 2 CFR 200.214, non-Federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred from participating in Federal programs. Prior to entering into a covered transaction, entities should verify that subrecipients are not suspended or debarred through SAM.gov, obtaining a certification from the subrecipient, or another method permitted by the regulations. Effective internal controls should be designed and implemented to ensure compliance with suspension and debarment requirements. Condition: The Organization did not maintain documented evidence demonstrating that suspension and debarment verification procedures were performed for covered transactions with vendors and subrecipients. Per inquiry with the Director of Finance and Operations, the Organization requires subrecipients to self-report their suspension and debarment status as part of the annual risk assessment process; however, the Organization does not perform or document independent verification procedures, such as reviewing SAM.gov, to confirm subrecipient eligibility. In addition, the Organization did not retain documentation evidencing that SAM.gov verification was performed prior to vendor selection, as management indicated such documentation had not previously been requested. Cause: Internal controls over suspension and debarment compliance were not designed and operating effectively to ensure that suspension and debarment verification procedures were independently performed and documented for covered transactions. Specifically, the Organization relied on self-certifications and informal verification procedures and did not maintain evidence demonstrating that suspension and debarment reviews were completed in accordance with Federal requirements. Effect: Failure to independently verify and document the suspension and debarment status of vendors and subrecipients increases the risk that the Organization could enter into covered transactions with ineligible entities, resulting in noncompliance with Federal requirements. Questioned Costs: Questioned costs were not identified. Perspective Information: During testing of suspension and debarment compliance, seven vendors and two subrecipients were selected for testing. The Organization was unable to provide documentation demonstrating that independent suspension and debarment verification procedures had been performed for the entities selected. As a result, we independently verified the suspension and debarment status of the vendors and subrecipients through SAM.gov and confirmed that none of the entities tested were suspended or debarred. No instances of noncompliance were identified. Repeat Finding: None. Recommendations: We recommend that management establish and document procedures requiring suspension and debarment verification for all covered transactions with vendors and subrecipients. Such procedures should include performing and retaining evidence of SAM.gov verification (or another method permitted by Federal regulations) prior to entering into covered transactions. Management should also incorporate supervisory review procedures to ensure suspension and debarment verifications are completed and documented in accordance with Federal requirements.

2025-003 Suspension & Debarment Cluster: Other major program referenced below Sponsoring Agency: Department of Health and Human Services Award Names: Doorway for Substance Use-Related Supports and Services Award Numbers: Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2024-2025 Pass-through entity: New Hampshire Department of Health and Human Services Criteria Per 2 CFR 200.214, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. The Dartmouth Health System’s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition In testing compliance with suspension and debarment requirements, PwC noted that 2 selections totaling $15.9k out of 9 selections tested totaling $53.5k did not have sufficient supporting documentation to evidence that required suspension and debarment procedures were completed prior to the related transaction and payment dates. For the items noted, the suspension and debarment checks were performed after the related transaction dates and payment dates. As a result, the Dartmouth Health System did not demonstrate that vendors were verified as not suspended or debarred before federal funds were disbursed. Management indicated that certain alternative verification procedures may have been performed prior to payment; however, documentation was not maintained to support that such procedures were completed timely. Cause While the Dartmouth Health System’s policy outlines the procedures to be followed for federal purchases, including required suspension and debarment checks, there was turnover within the procurement function for Cheshire Medical Center. Therefore, instances were identified in which a suspension and debarment check was not performed prior to the transaction. Effect The lack of adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Repeat Finding No Recommendation We recommend the Dartmouth Health System ensure that timely suspension and debarment verifications are completed in line with policy. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.

Condition SCORE has an established procedure requiring review of vendors in the System for Award Management (SAM.gov) to ensure vendors are not suspended or debarred prior to engagement using federal funds. During our testing of suspension and debarment for new and renewed contracts, we noted that the documentation provided as evidence that SCORE conducted the required checks did not consistently include clear evidence that vendors were verified in SAM.gov for suspension, debarment, and active registration status at the time of award or renewal. In several instances, the documentation provided lacked dated SAM.gov search results or other proof of verification, making it difficult to confirm the date the required eligibility checks were completed before obligating federal funds. Additionally, for multi-year or continuing contracts, certain vendors that were originally vetted at the time of initial engagement did not have documented evidence of a subsequent suspension and debarment verification. Criteria Federal procurement standards require non-Federal entities to: ▪ Verify that vendors are not suspended or debarred prior to entering into or renewing an agreement (2 CFR § 180 and § 200.214). ▪ Maintain complete procurement documentation, including approvals, selection methods, contract documents, and evidence of compliance with procurement rules, in accordance with Uniform Guidance procurement requirements (2 CFR § 200.318–327). A SAM.gov verification—via screenshot, printout, or automated system—is an acceptable form of documentation. Cause While SCORE has implemented procedures to verify new vendors through SAM.gov, the procedures did not explicitly require periodic verification for existing vendors whose contracts continue across multiple years or are renewed. Also, while personnel may be performing eligibility checks for new vendors, there is no standardized requirement or checklist to ensure that proof of the verification (such as dated screenshots or search results) is consistently saved. Effect As a result, the organization lacks sufficient documentary evidence to demonstrate that the required SAM.gov verifications were performed at the time of contract award or renewal. Although no vendors were identified as suspended or debarred, the absence of supporting documentation limits the organization’s ability to substantiate compliance with federal procurement requirements. Also, there is a risk that an existing vendor could become suspended or debarred after the initial contract award and continue to receive payments without updated verification. Recommendation We recommend that SCORE expand its existing vendor compliance procedures to include periodic verification of suspension and debarment status for multi-year or continuing service agreement vendors. We also recommend that management implement a standard procedure requiring documentation of dated SAM.gov verification for all vendors prior to contract award and renewal. These dated SAM.gov verifications should be retained as part of the vendor file.

Criteria—According to the Coronavirus State and Local Recover Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition—During our testing, it was noted that 1 of 3 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause—The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect—In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation—We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.

Finding No.: 2025-012 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.267 Continuum of Care Program Federal Award No.: GU0018L9C002209, GU0026L9C002305, GU0028L9C002204, GU0037L9C002201, GU0031L9C002203 Area: Procurement and Suspension and Debarment Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.214 states: Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. 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. 2 CFR 200.318(h) states: (h) Responsible contractors. The recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully under the terms and conditions of a proposed contract. The recipient or subrecipient must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources when conducting a procurement transaction. Condition: Of seven items tested, totaling $288,950 out of $1,053,179 in expenditures subject to suspension and debarment testing, five subawards (71%) lacked evidence of the required verification, as follows: Item # Federal Award No. Vendor No. Expenditures Questioned Costs 1 GU0018L9C002209 LL00000078 $ 40,015 $ 40,015 2 GU0026L9C002305 LL00000078 43,917 43,917 3 GU0028L9C002204 VN000HAPP 118,418 118,418 4 GU0037L9C002201 VN00092963 59,368 59,368 5 GU0031L9C002203 VN00200326 27,232 27,232 $288,950 $288,950 Finding No.: 2025-012, continued Cause: Management has not established formal procedures or documented guidelines requiring verification of vendor suspension/debarment status as part of the awarding process. Effect or potential effect: GHURA is in noncompliance with applicable suspension and debarment requirements. Questioned costs: $288,950 Identification as a repeat finding: Not applicable. Recommendation: Responsible management should establish and consistently enforce formal procedures requiring the retention of all subaward-related documentation, including documented verification of entity eligibility (e.g., SAM.gov checks) and applicable certifications, within the subrecipient file. Views of Responsible Officials: Management concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan.

Finding No.: 2025-015 Identification of Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) AL Program: 14.850 Public Housing Operating Fund Federal Award No.: GQ00100000125D, GQ00100000225D, GQ00100000325D, GQ00100000425D Area: Procurement and Suspension and Debarment Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.214 states: Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. 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. GHURA Procurement Policy, Chapter VII further states: For all purchases above the Petty Cash/Micro Purchase threshold, GHURA shall prepare an Independent Cost Estimate (ICE) prior to solicitation. The level of detail shall be commensurate with the cost and complexity of the item to be purchased. 2 CFR 200.319(a) states: All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and § 200.320. GHURA Procurement Policy, Chapter IV, Sealed Bids, Section D further states: Noncompetitive–contracts: If only one responsive bid is received from a responsible bidder, award shall not be made unless the price can be determined to be reasonable, based on a cost or price analysis and that GHURA obtains HUD approval for contracts exceeding the Simplified Acquisition Threshold or the GHURA's small purchase limit, whichever is less. Finding No.: 2025-015, continued Condition: For twenty-one (72%) of twenty-nine items examined, aggregating $236,001 of $1,508,875, in total expenditures of $1,543,721 subjected to procurement, suspension and debarment tests, deficiencies were noted, as follows: Item # Project No. Purchase Order No. Expenditures Questioned Costs 1 GQ001000003 PO250839 $ 55,700 $ 55,700 2 GQ001000001 PO250018 46,020 46,020 3 GQ001000002 PO250047 33,600 33,600 4 GQ001000001, GQ001000002 GQ001000003, GQ001000004 PO250373 26,371 26,371 5 GQ001000001 PO251763 12,316 12,316 6 GQ001000003 PO251249 2,761 2,761 7 GQ001000002 PO251207 2,730 2,730 8 GQ001000004 PO250955 2,562 2,562 9 GQ001000004 PO250153 2,365 2,365 10 GQ001000003 PO250104 2,123 2,123 11 GQ001000004 PO250572 1,230 1,230 12 GQ001000004 PO250156 1,100 1,100 13 GQ001000002 PO250111 914 914 14 GQ001000002 PO251224 672 672 15 GQ001000004 PO251679 651 651 16 GQ001000002 PO250753 560 560 17 GQ001000004 PO251266 542 542 18 GQ001000004 BPA250133 7,240 7,240 19 GQ001000002 BPA250008 3,500 3,500 20 GQ001000003 BPA250203 3,333 3,333 21 GQ001000002 BPA250025 500 500 $ 206,790 $ 206,790 For item #s 1 through 4, there was no documentation on file to support that GHURA performed procedures to ensure contracting parties are not debarred, suspended, or excluded from receiving or participating in federal awards. For item #s 1 through 21, there was no documentation on file to support that GHURA performed Independent Cost Estimate (ICE) procedures prior to solicitation. For item # 8, there was no documentation on file to support that GHURA conducted the continued procurement of services beyond the contract extension in a manner that ensured adequate competition or proper justification. Finding No.: 2025-015, continued Condition, continued: For item # 16 and item #s 20 and 21, there was no documentation (e.g. solicitations) on file to support the procurement transactions being conducted in a manner that provided for full and open competition. Specifically, there was no evidence of solicitations being issued or documentation on file to justify the use of noncompetitive procurement. For item #s 19 through 21, there was no documentation (e.g. solicitations) on file to support the procurement transactions being conducted in a manner that provided for full and open competition. Specifically, the procurement file lacks evidence of minimum solicitation to support fair competition and does not demonstrate that blanket purchase orders for towing and advertisement services were awarded equally among multiple vendors. Cause: GHURA did not have adequate monitoring controls in place to ensure compliance with applicable procurement, suspension and debarment requirements. Specifically, policies and procedures were not established or enforced to ensure verification and documentation that contracting parties were not suspended or debarred. In addition, procurement personnel did not follow required policies and procedures requiring minimum solicitation and justification for noncompetitive procurement, and management review did not detect or prevent these deficiencies. Effect or potential effect: GHURA is in noncompliance with applicable procurement, suspension and debarment requirements. Questioned costs: $206,790 Recommendation: 1. Responsible management should establish and consistently enforce formal procedures requiring the retention of documented verification of eligibility (e.g., SAM.gov checks) and applicable certifications within the procurement file. Additionally, management should ensure that, prior to the execution of contracts, all agreements include the required suspension and debarment clause to demonstrate compliance with suspension and debarment requirements. 2. Establish controls to ensure required documentation (Independent Cost Estimates, proper justification, etc.) is prepared, documented, and maintained in the procurement file prior to solicitation for all applicable procurements. Finding No.: 2025-015, continued Views of Responsible Officials: Management partially concurs with the finding. Refer to Management’s position as outlined in the Corrective Action Plan. Conclusion: Management submitted additional information on June 28, 2026; however, due to time constraints, we were unable to sufficiently corroborate and evaluate the documentation provided. Accordingly, the finding remains, as there was insufficient evidence to support a determination of compliance as of the audit date.

Procurement and Suspension and Debarment Federal Agency: U.S. Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund (DWSRF) ALN: 66.468 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2521902915 September 1, 2024 - August 31, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: "Per 2 CFR §200.303(a), Texas Commission on Environmental Quality (TCEQ) must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align 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). Per 2 CFR §200.318, the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Per 2 CFR §200.214, recipients and subrecipients are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. 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: Audit procedures included a review of five procurements conducted during the fiscal year to assess whether TCEQ adhered to required procurement procedures and performed vendor eligibility verifications prior to entering into covered transactions. For one procurement, totaling $16,175, the required procurement processes were not followed, and the necessary vendor compliance checks, including verification of suspension and debarment status, were not completed before executing the transaction. Questioned costs: None. Context: See “Condition.” Cause: The procurement was initiated directly by the program area without notifying or coordinating with the Procurement and Contracts Section. Program staff proceeded with the purchase under the assumption that procurement involvement was unnecessary because the selected vendor was the sole provider of the required item. As a result, established procurement procedures and vendor compliance verification processes were not followed. Effect: Failure to follow procurement procedures and complete proper vendor compliance checks prior to entering into a covered transaction may lead to entering contracts with suspended or debarred vendors that could result in noncompliance and questioned costs. Repeat Finding: No Recommendation: TCEQ should provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the P&C Section and completing required vendor compliance checks. Training should emphasize procedures for sole‑source or limited‑source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Views of responsible officials: The Financial Administration Division (FAD) will implement the audit’s recommendations. FAD will reinforce the guidance provided through continuous training, documentation, and improved internal controls.

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: American Rescue Plan Act - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: City of Pasco Pass-Through Number(s): N/A Award Period: July 26, 2024 – September 2, 2026 Type of Finding:  Significant Deficiency in Internal Control Over Compliance – Suspension & Debarment  Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards §200.214 requires non-Federal entities to ensure that contractors are not suspended or debarred prior to entering into covered procurement transactions and to maintain controls to verify compliance with suspension and debarment requirements. Condition: Verification was not formally documented. As such, we were unable to verify this was performed prior to engaging with the contractors. Questioned costs: None. Context: Suspension and debarment verification support from SAM.gov was not retained, and no documentation was available to evidence that verification procedures were performed prior to the Club engaging with the contractors. Cause: Management did not retain documentation evidencing the performance of suspension and debarment verification procedures. Effect: The Club did not have documented evidence to demonstrate compliance with suspension and debarment verification requirements. Repeat finding: Not a repeat finding. Recommendation: We recommend the Club establish and retain documentation to evidence that suspension and debarment verification procedures are performed prior to engaging with contractors. Views of responsible officials: There is no disagreement with the audit finding.

FINDING 2025-001 SUSPENSION AND DEBARMENT SIGNIFICANT DEFICIENCY Federal Program: Charter Schools Program Assistance Listing Number: 84.282A Criteria 2 CFR 200.214 states that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. 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 The School does not have a policy in place outlining the process to check that vendors are not suspended or debarred. Additionally, the School could not support that these checks were being completed for vendors paid using federal program funds. Cause The School was not aware of the requirement to check vendors for suspension and debarment. Effect Failing to check vendors for suspension and debarment could result in improperly paying vendors with funds from federal sources. Recommendation We recommend the School develop a policy and internal controls to ensure vendors paid with federal funds are checked for suspension or debarment. Views of Responsible Officials The School’s Corrective Action Plan is included on page 26.

Child Nutrition Cluster - Procurement - Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Commodities, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of responsible officials and planned corrective actions: The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.

Child Nutrition - Procurement - Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, Snack, non-cash commodities, Summer Food Service Program, Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis for the school lunch fund vendors. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of vendors charged to the school lunch fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.

Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, non-cash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District was able to obtain information through the bidding process that the vendor had been reviewed for suspension and debarment, they also ensured the District’s vendors charged to the fund, were not suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of Responsible Officials and Planned Corrective Actions: The District acknowledges the finding and agrees with the recommendation. To address this issue the Business Office will verify all vendors used in federally funded programs at least once annually and prior to disbursing funds. Michele Hogan and April Young will be responsible with an anticipated completion date of September 30, 2025. Staff will review both 2 CFR Section 200.214 and 2 CFR Part 180 for understanding and compliance. Michele Hogan and John Lybert will be responsible with an anticipated completion date of September 30, 2025.

Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing Numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR Part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Perspective Information: As part of the requirements under the Uniform Guidance, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The Business Manager will review these requirements with the Sr. Account Clerk. The Sr. Account Clerk will verify that all vendors are eligible to participate in the federal assistance program on an annual basis. Specifically, a note will be entered on the vendor record in the accounting system each time a purchase order is issued, which will detail that the proper verification was performed.

Child Nutrition Cluster - Procurement. Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures; as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR part 180 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure procurement procedures are being followed. Further, the District will perform and document a review of the eligibility of vendors to participate in Federal assistance programs. The District is in the process of corrective action, and is working toward compliance.

Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, noncash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. U.S. Department of Education Special Education Cluster (Special Education – Grants to States and Special Education – Preschool Grants Assistance Listing Numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Additionally, we noted that there was no verification that procurements through state contracts were invoiced to the District at the contract rates. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. The District could also be overpaying for goods. Questioned Costs: None Perspective Information: A review of vendors charged to the major programs determined no vendors were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Additionally, we recommend that a review of invoices as compared to bidding/contracting documentation be performed prior to payment. Views of responsible officials and planned corrective actions: Effective July 1, 2025 the Executive Director of Business & Human Resources, Kevin J. Polunci will review and and verify the eligibility of vendors that participate in federal assistance programs and on an annual basis. Additionally, the District will review the eligibility of potential vendors that participate in federal assistance programs and compare invoices to bidding/contracts prior to payments.

Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Lunch Program, School Breakfast Program, non-cash commodities, Summer Food Service Program, Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis for all school lunch vendors. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of all vendors charged to the school lunch fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 20.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials: The District will begin verifying the status of all vendors paid with federal funds to ensure they are not suspended or debarred.

Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children Assistance Listing numbers 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.314 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Also as part of the required follow up of prior year audit findings, inquiries were performed to determine if bidding and procurement procedures were being followed, and they were not. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.

2025-003: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: IDEA Special Education Federal ALN: 84.027/84.173 Criteria: Under 2 CFR §200.318-§200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition and must follow documented procurement procedures consistent with federal standards. Additionally, 2 CFR §200.214 (previously §200.213) requires non-federal entities to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing of procurement transactions, we identified two (2) contracts in which bids were not solicited as required by the District's procurement policy and Uniform Guidance. In addition, suspension and debarment checks were not performed or documented for these vendors prior to contract award. Cause: The exceptions occurred because procurement procedures were not consistently followed, and management did not perform or document required suspension/debarment verifications prior to contract execution. This may have been due to oversight or lack of staff training regarding Uniform Guidance procurement requirements. Effect or Potential Effect: Failure to solicit bids and perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs charged to federal programs, and diminished assurance that contracts are awarded fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Solicit bids or proposals in accordance with applicable competitive procurement thresholds; - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.

Special Education Cluster – Procurement Information on Federal Program: U.S. Department of Education Special Education Cluster (Special Education – Grants to State (IDEA, Part B) and Special Education – Preschool Grants (IDEA Preschool) Assistance Listing numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the special education cluster and therefore represents purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. The District did perform a retrospective review of all vendors associated with federal grants, and encountered no vendors that were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: Effective September 2025, the District has implemented a procedure to perform this review on vendors associated with federal grants annually.

U.S. Department of Treasury Federal Assistance Listing #21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, & Debarment Material Weakness in Internal Control Over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.318 requires the auditee to use its own documented procurement procedures which reflect State, local and tribal laws and regulations, provided that the procurements conform to applicable Federal law and standards. 2 CFR 200.214 restricts making federal awards with certain parties that are debarred, suspended, or otherwise excluded from participating in Federal awards. Condition: The Hospital did not have a written procurement policy in place that aligned with all federal regulations. The Hospital also did not review vendors to ensure that they were not debarred, suspended, or otherwise excluded from participating in federal awards. Cause: While the Hospital did have a policy in place, the policy did not follow all federal regulations, or include policies of determining if vendors are debarred, suspended, or otherwise excluded from participating in Federal awards. Effect: Noncompliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: None reported Context: A nonstatistical sample of 3 vendors out of 9 vendors with actual or anticipated expenditures greater than the federal micro purchase threshold were tested for procurement testing. Repeat Finding from Prior Years: No. Recommendation: The Hospital should update their procurement policy to align with all federal requirements outlined in 2 CFR 200.318. We also recommend that the Hospital reviews vendors that are used for federal awards to ensure that they are not debarred, suspended, or otherwise excluded from participating in Federal awards in accordance with 2 CFR 200.214. Views of Responsible Officials: Management agrees with the finding.

Reference Number: 2025-006 Program Name: Special Education Cluster Description: Procurement, Suspension and Debarment Condition: During our testing of procurement, the District did not retain documentation demonstrating the suspension and debarment status of two (2) vendors paid. While the District verbally stated that SAM.gov checks were performed, no evidence was available for examination. Criteria: 2 CFR 200.214 requires Districts to ensure, and retain evidence, that the verification process was complete. Verification can be documented through 1) a screenshot or printout from SAM.gov, 2) An official certification from the vendor, or 3) a written record the verification was completed. Cause: The District’s procurement policy does not formally state that retention of the search is required. Effect: The District can’t demonstrate compliance with federal procurement requirements. Questioned Costs: None. Identification of a Repeat Finding: This is not a repeat finding. Auditors’ Recommendation: We recommend that the District update their procurement policy to include that retention of the search is required. Views of Responsible Officials: See attachment for District’s corrective action plan.

2025: Procurement Procedures (Significant Deficiency and Noncompliance) Federal Program: American Recovery Plan Act Federal ALN: 21.027 Criteria: Under 2 CFR 200.214 (previously 200.213) requires the City to verify that contractors are not suspended or debarred from doing business with the federal government. This verification may be accomplished by checking the System for Award Management (SAM.gov) or obtaining a certification from the vendor. Condition and Context: During our testing, we identified two (2) transactions for which suspension and debarment checks were not performed or documented prior to contract award. Cause: Undetermined. Effect or Potential Effect: Failure to perform suspension/debarment checks increases the risk of noncompliance with federal regulations, potential ineligible costs changed to federal programs, and diminished assurance that contracts are awards fairly and to responsible parties. Questioned Costs: None. Identification as a Repeat Finding: No. Recommendation: We recommend that management strengthen procurement procedures to ensure compliance with Uniform Guidance requirements. Specifically: - Perform and document suspension and debarment checks (e.g., through SAM.gov) prior to awarding contracts; and - Provide staff training on federal procurement standards and maintain documentation supporting compliance for each federally funded procurement. Responsible Official's Response: Please see the last page of this report for the response to this finding.

2025-002 Special Education Cluster: Suspension and Debarment Federal Agency: United States Department of Education Federal program Name: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number and Year: Unknown Pass-through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024/2025-585264-DPI-FLOW-341, 2024/2025-585264-DPI-PRESCH-347 Award Period: 07/01/2024 – 06/30/2025 Compliance Requirements Affected: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing we noted the District does not have a consistent procedure in place for verifying that vendors are not debarred, suspended, or otherwise excluded. Questioned costs: None Context: In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for two of the four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement and Suspension and Debarment Policy related to appropriate methods of procurement and suspension and debarment. Effect: The District could contract with a vendor that has been suspended or debarred from receiving Federal Funds. Repeat Finding: 2024-005 Recommendation: We recommend that the District reviews its procedures to ensure the District’s suspension and debarment policy is being consistently followed. We further recommend that the District requires all grant administrators to receive training on Federal suspension and debarment regulations. View of Responsible Officials: There is no disagreement with this audit finding. See corrective action plan.

Finding: 2025-003 Procurement, Suspension, and Debarment (Significant Deficiency) Federal Agency(ies): United States Department of Agriculture Federal Program(s): Partnerships for Climate-Smart Commodities Assistance Listing Number(s): 10.937 Pass-through Entity (if applicable): N/A Award Identification Number and Year: NR233A750004G045 (2023) Criteria or Specific Requirement:  2 CFR 200.320(a)(1)(iv) allows for an increased micro-purchase threshold of up to $50,000 only if the non-Federal entity self-certifies that it meets specific conditions, including internal controls, organizational risk, and procurement oversight capacity.  2 CFR 200.214 prohibits contracting with or making subawards to parties that are suspended or debarred, and entities are required to verify that contractors are not listed on the System for Award Management (SAM.gov) at the time of contact/award.  2 CFR 200.318(c)(1) requires non-Federal entities to maintain written standards of conduct covering conflicts of interest and governing the performance of employees engaged in the selection, award, and administration of contracts. Condition: Our testing identified the following exceptions: 1. CIF did not maintain a comprehensive written procurement, suspension, and debarment policy during the fiscal year under audit. A draft policy was developed during the audit planning phase and is pending approval from the Board of Directors. 2. The draft policy self-certified a micro-purchase threshold of $50,000, which is not appropriate given that CIF does not meet all criteria required under 2 CFR 200.320(a)(1)(iv), and the elevated threshold is excessive relative to the size and scope of the Organization’s operations. 3. CIF provided SAM.gov suspension and debarment checks for contractors in our sample; however, the checks were undated, and we were unable to confirm that the verification was performed at the time of contract execution. 4. CIF did not maintain a conflict of interest policy during the fiscal year under audit, as required by 2 CFR 200.318(c)(1). While a draft conflict of interest policy was included in the draft procurement policy, it was not in effect during the year under audit. Cause: These conditions occurred because the Organization did not have formalized procurement policies and procedures in place throughout the year. Effect or Potential Effect: Failure to maintain compliant procurement and conflict of interest policies and procedures increases the risk that Federal funds may be spent in a manner inconsistent with Uniform Guidance requirements. Questioned Costs: $172,572 (all contractual expenses changed to ALN #10.937) Context: We tested a statistically valid sample of contractual relationships charged to Federal awards. The deficiencies noted were consistent across the sample population, indicating a systemic issue rather than isolated exceptions. Identification as a Repeat Finding, if Applicable: Yes, repeat of Finding 2024-006Recommendation: We recommend that management: 1. Finalize and implement a comprehensive procurement, suspension, and debarment policy that incorporates all requirements of 2 CFR 200.318–200.320. 2. Amend the draft policy to adopt a micro-purchase threshold appropriate for the Organization’s size and risk profile, consistent with 2 CFR 200.320(a)(1)(iv). 3. Ensure that SAM.gov checks are performed and documented with date-stamps at the time of contract execution. 4. Adopt and enforce a formal conflict of interest policy as required by 2 CFR 200.318(c)(1), and amend the policy to require annual (written) reaffirmations from all employees and Board members.

Criteria: Uniform Guidance (2 CFR §200.214 and §200.318(h)) prohibits non-federal entities from contracting with or making subawards to parties that are suspended or debarred. Entities must verify vendor eligibility by: Checking SAM.gov, Obtaining a vendor certification, or Adding a clause in contracts stating the vendor is not suspended or debarred. Condition: The Town did not have adequate internal controls to ensure compliance with the suspension and debarment requirements of the Uniform Guidance when procuring goods or services using federal funds. Cause: The Town had not established written procedures or implemented controls to ensure required suspension and debarment checks were performed and documented during procurement involving federal funds. Effect: Without controls to ensure compliance with suspension and debarment requirements, the Town is at increased risk of awarding federal funds to ineligible vendors. This could result in unallowable costs, questioned costs, or potential repayment of federal funds. Recommendation: The Town should develop and implement written policies and procedures requiring documentation of suspension and debarment checks before entering into contracts funded with federal awards. Acceptable methods include maintaining SAM.gov eligibility verification screenshots, obtaining vendor certifications, or including appropriate contract language. Views of responsible officials: See management’s responses to findings on Page 78.

74 Section III - Findings and Questioned Costs for Federal Awards (Continued) Significant Deficiency 2025-002 - PROCUREMENT, SUSPENSION & DEBARMENT: Procurement Policy Federal Program Information: US Department of Agriculture Direct Award ALN: - 10.760 Water and Waste Disposal Systems for Rural Communities Criteria: Per 2 CFR Section 200.214, non-federal entities are subject to the nonprocurement and suspension regulations restricting awards, subawards, and contracts with certain parties that are debarred or suspended. Condition: The Town does not have a formal procedure to determine that contractors are not debarred, suspended or otherwise excluded or ineligible for participation in Federal assistance programs or activities. Cause: The Municipality is working on adopting an updated federal procurement policy in response to the prior year finding, but it has not been adopted yet. Effect: Transactions could occur that did not comply with federal regulations. Identification of Questioned Costs: None identified. Context: The finding was based on requesting the Town’s policies and procedures related to federal compliance and therefore was not the result of a statistical sample. Repeat Finding: This is a repeat finding of 2023-003. Recommendation: The auditor recommends that the Town obtain an understanding of the required procedures in the Code of Federal Regulations as applicable to its federal programs, create and formally adopt those required procedures. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by Town of Bridgewater, Vermont.

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2025 Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The city did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The city does not have procurement policies and procedures in place that allows it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.

2025-006 Procurement, Suspension & Debarment – Special Education Cluster (IDEA) Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Wisconsin Department of Instruction Pass Through Numbers: 2025-445138-DPI-ES3-342, 2025-445138-DPI-FLOW-341, 2025-445138-DPI-PRESCH-347 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Material Weakness in Internal control over Compliance, Material noncompliance (Qualified Opinion) Criteria or specific requirement: 2 CFR 200.320 Methods of Procurement state that if the small purchases method is used, price or rate quotations must be obtained from an adequate number of qualified sources (at least 2). Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical. Additionally 2 CFR 200.214 requires non-Federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a non-Federal entity enters into a covered transactions with an entity at a lower tier, the non-Federal entity must verify that the entity, as described in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our testing of procurement transactions of the program, we noted that the District was not consistently following the procurement policy, specifically related to small purchases threshold. These purchases were not supported by an adequate number of quotes (at least two) or proposals to ensure the District is prudent with the monies used towards the program. Additionally, we noted the District does not have procedures in place for verifying that vendors are not debarred, suspended or otherwise excluded. Questioned Costs: None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) Context: During our testing of procurement transactions of the program, we noted the District was not consistently following the procurement policy, specifically related to small purchases threshold. In our sample of 3 vendors subject to procurement requirements, we noted the District did not obtain and/or retain documentation for an adequate number of price quotes for two vendors. In our testing of suspension and debarment, we noted that the District did not retain documentation related to suspension and debarment for all four vendors that were selected for testing. Cause: The District did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the District to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the District to over pay for supplies or services. Additionally, the District could contract with a vendor that has been suspended or debarred from receiving Federal funds. Repeat Finding: No Recommendation: We recommend the District review their policies and procedures related to Uniform Guidance and the District's Purchasing Policy. We also recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Views of Responsible Officials: There is no disagreement with the finding.

2025-001 –Procurement, Suspension and Debarment Cluster / Program: Research & Development (R&D) / ALN 19.UO9, 19.U10: The MITRE Corporation – U.S. Department of State Grantor: - Defense Advanced Research Projects Agency (DARPA) / DoD, National Science Foundation (NSF) / U.S. Department of State Award Name: EE Tang MPI PennST DARPA Monolithic GaN, Social Networks and Migration in Nepal / Conflict Observatory – Sudan, Conflict Observatory – Ukraine Award Number: AWD0011529, AWD0007921 / AWD0011946, AWD0010905 Award Year: FY2025 Assistance Listing Numbers: 12.910, 47.075 / 19.U09, 19.U10 Assistance Listing Titles: Research and Technology Development, Social, Behavioral, and Economic Sciences / U.S Department of State Pass-Through Entities: N/A / Pennsylvania State University Criteria Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition We selected a sample of 25 transactions within the R&D cluster and 5 transactions within ALN 19.U09, 19.U10 and noted two selections within R&D cluster and one selection within ALN 19.U09, 19.U10 where debarment checks were not performed prior to entering into the transaction. Cause Due to the manual nature of the debarment checks, there was an oversight and the vendors were not screened at the time of set up due to human error. Effect New vendors are not consistently checked for suspension and debarment prior to the University entering into a transaction with the vendors as required by the regulation stated above. Questioned Costs None noted. Repeat Finding in the Prior Year No Recommendation PwC recommends additional training for employees responsible for suspension and debarment checks to ensure established procedures are followed when entering into a covered transaction with an entity. Additionally, we recommend considering an automated process where when a new vendor is entered into the system, a debarment check is automatically initiated.

FINDING 2025-002 Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listings Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-010-PN01, 22611-010-PN01, 23611-010-PN01, 24611-010-PN01, 22611-010-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., a grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the School Corporation in order to review the procedures in place for verifying that a person with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the School Corporation did provide documentation that suspension and debarment requirements were verified for one of the tested vendors. No documentation was provided for the remaining covered transactions, totaling $329,876. The lack of proper internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 18 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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 be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.214 states: "Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure all vendors to whom payments equal to or in excess of $25,000 were verified prior to entering into subawards and covered transactions. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were not all verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provision of federal statutes, regulations, and terms and conditions of the federal award could result in the reduction of future federal funding to the School Corporation. INDIANA STATE BOARD OF ACCOUNTS 19 EAST ALLEN COUNTY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish and implement an effective system of internal controls to ensure all vendors to whom payments equal to or in excess of $25,000 are verified prior to entering into subawards and covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.