Findings Citing § 200.214

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.

2025-001 U.S. Department of Education, Assistance Listing #84.027/84.173 Special Education Cluster (IDEA) Program and U.S. Department of Treasury, Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds (SLRF) Program for the period of July 1, 2024, through June 30, 2025 Criteria: Uniform Guidance section 2 CFR §200.317-200.327 Procurement Standards, requires purchases exceeding the micro-purchase threshold of $10,000 to follow small purchase procedures, which require obtaining price or rate quotations from an adequate number of qualified sources (§200.320) prior to entering into a contract. In addition, 2 CFR Part 180 and 2 CFR §200.214 require non-federal entities to verify if contractors are suspended or debarred (e.g., Sam.gov check or certification) and include appropriate contract clauses in applicable contracts. Condition: The School Department did not obtain price or rate quotations for two projects that exceeded the micro-purchase threshold. Additionally, the Department did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses). The City did not perform, or document required suspension and debarment procedures for the contractor (e.g., verification against SAM.gov, obtaining certifications, or including contract clauses) for three of the six contracts tested. Cause: School staff were not aware the projects would be funded with federal funds and did not ensure compliance with federal requirements for competitive pricing and suspension/debarment verification. City staff were not aware projects covered under the SLRF definition of “revenue replacement”, which excludes most procurement requirements, are still required to follow 2 CFR Part 180 and 2 CFR §200.214. Effect: Failure to obtain competitive quotes and verify contractor eligibility to receive Federal funds increases the risk of noncompliance, inefficient use of federal funds, and potential disallowance of costs. Known Questioned Costs: $61,891 for #84.027/84.173; $51,750 for #21.027 Likely Questioned Costs: $12,799 for #21.027 Recommendation: We recommend training staff on procurement and suspension/debarment requirements and implementing a pre-award compliance checklist. We also recommend increasing communication between grant personnel and facilities management personnel so all parties are aware which projects will be funded with federal funds.

Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - H4HRGP33345 Pass-through Entity - State of Colorado, Department of Local Affairs, for the benefit of the Division of Housing 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 was maintained evidencing the organization's verfication that contractors are not suspended or debarred from participating in a federally funded activity. 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 the organization's 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 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 one federal program under the Coronavirus State and Local Fiscal Recovery Funds program (Assistance Listing 21.027), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained in the contract file. This represents a documentation lapse rather than a control deficiency. Volunteers of America Colorado (VOAC) 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 micro purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $10,000. To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following corrective actions: 1.Policy Enhancement: The procurement procedure has been updated to explicitly require saving and retaining a time stamped screenshot or PDF confirmation of each SAM.gov verification showing the verification date and results. Where applicable, contractors subject to 2 CFR 200.214 must also provide a self certification statement within the executed agreement. 2.Centralized Recordkeeping: Verification evidence will be maintained in both the individual contract file and the centralized grant management system. 3.Annual Training and Refresher: Procurement and grants management staff will participate in annual training to reinforce 2 CFR 200.214 requirements and best practices for documentation and record retention. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and that the actions taken since have resolved the issue and will ensure continued compliance.

Compliance Requirement: Procurement, Suspension and Debarment Campus:Sacramento Cluster name/program: Supplemental Nutrition Assistance Program Cluster Federal Assistance Listing Numbers: 10.561 Federal Award Identification Number: 21-3068 and 24-3069 Federal Agency: U.S. Department of Agriculture Passed through Entity: State of California Department of Social Services Award Year: July 1, 2024 – June 30, 2025 Criteria: According to 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. Additionally, 2 CFR 180.300 requires non-federal entities (including state agencies administering federal programs like SNAP) to verify that contractors and subrecipients are not suspended or debarred from receiving federal funds CFR 200.303 also requires nonfederal entities to, among other things, 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. Condition and Context: During our testing of 2 procurement samples, it was noted that the program personnel did not check if the vendors were suspended or debarred from receiving federal funds before entering into a covered transaction, nor was a certification from the vendor about verification of suspension and debarment collected from the vendor. We noted the vendors were not suspended or debarred and there were no other exceptions noted in the procurement, suspension and debarment testing. Cause and Effect: The control over the verification that vendors are not suspended or debarred prior to entering into a covered transaction was not designed effectively. As such, the suspension and debarment check requirements were not implemented for all procurement methods for this program. Questioned Costs: None Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No Recommendations: We recommend the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Views of Responsible Officials: The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor.

FINDING 2025-002 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 15 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $150,000 per Indiana Code. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases of $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The School Corporation had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchases were followed. The School Corporation did not obtain price or rate quotes from multiple vendors for its audit period expenditures with each of the three vendors tested in the small purchases category. Documentation detailing the history of procurement, including rationale to limit competition at the time of the expenditure(s) was not provided for audit. Suspension and Debarment Nonfederal entities and contractors are subject to nonprocurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or are ineligible for participation in federal assistance programs or activities. This is done by checking SAM Exclusions, collecting a certification from that entity, or adding a clause or condition to the covered transaction with that entity. The School Corporation had not designed or implemented adequate policies or procedures to ensure that applicable vendors who received federal funds over certain thresholds were not suspended or debarred from participating in federal awards programs. There were three vendors subject to suspension and debarment requirements during the audit period that were not procured through the School Corporation's affiliated Educational Services Center for cooperative purchasing. The School Corporation did not perform procedures to ensure the vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in federal assistance programs or activities for one of these three vendors. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to small purchases for procurement and one vendor noted for suspension and debarment. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. . . . (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small Purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." 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." 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 INDIANA STATE BOARD OF ACCOUNTS 17 CLOVERDALE COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause Management had not developed nor implemented an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. The Food Service Director indicated that some of these purchases may have been emergency situations but was unaware of the need to document the rationale at the time of the transaction if competition was limited for small purchases procurements. Effect The lack of an internal control system enabled material noncompliance to occur and remain undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could enable small purchases made by the School Corporation to be uncompetitive and could lead to contracting with vendors who are suspended or debarred from receiving federal grant funding. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management strengthen its system of internal controls over small purchase requirements to ensure that an adequate number of price or rate quotes are obtained before purchase. Additionally, if procurements are made in emergency or extenuating circumstances, documentation at the time of the transaction must be retained for audit to justify limiting competition. We also recommended that vendors with a single or aggregate transaction amounts of $25,000 per fiscal year are verified for suspension and debarment prior to entering into the transaction and/or contract. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.214 specifies that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations related to subawards and contracts with certain parties. The non-federal entity must have controls in place to ensure subawards and contracts are not entered into with suspended or debarred parties. Condition: Verification support did not indicate the date verification procedures were performed. As a result, we were unable to verify this was performed prior to engaging with the contractor. Questioned costs: None. Context: Suspension and debarment verification support from SAM.gov did not explicitly state the date the verification procedures were performed. Support was not available to ensure verification procedures were performed prior to the date CAPECO engaged with the contractor. Cause: During the verification process, management failed to include a date stamp for the online print out to support the date the verification procedures were performed. Effect: Suspension and debarment verification support from SAM.gov did not explicitly state the date the verification procedures were performed. Repeat finding: Not a repeat finding. Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Views of responsible officials: There is no disagreement with the audit finding.

2025-001 – Suspension and Debarment (repeat comment) Finding Type: Significant deficiency in internal control over compliance Program: ALN 97.044 – Assistance to Firefighters Grant • Grant number EMW-2022-FG-01118 • Grant number EMW-2023-FG-03417 • Grant number EMW-2023-FG-02529 Criteria: As required by 2 CFR 200.214, 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 receiving or participating in Federal awards. Condition: The vendors used for these grants were not checked for suspension and debarment prior to execution of the contract. Cause/Effect: Although a policy has been adopted requiring a check the suspension and debarment status prior to entering into contracts, the internal control over this process was not operating as designed. Questioned Cost: None. Recommendation: We recommend that the City update procedures to ensure that a check of suspension and debarment status is obtained prior to entering into a covered transaction. View of Responsible Official: Management is in agreement with this recommendation.

2025-001 – Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through AI-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct 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: For 1 of 25 new vendors sampled, the vendor was not included in the ongoing suspension and debarment monitoring process, which is performed via a third-party servicer. Upon further discussion with the University, it was determined that the selected vendor was part of one day where a total of an additional 24 new vendors were also excluded from the ongoing process. Of the 25 total vendors, 3 of these vendors incurred expenditures related to federal awards totaling approximately $7,000 during the fiscal year. Cause: There was a system failure on one specific day between the University and the third-party servicer that prevented the suspension and debarment checks from being performed on new vendors. After the system failure, University personnel did not confirm that new vendors that were intended to be added on the date in question, were in fact added to the system. Effect: New vendors were not checked for suspension and debarment prior to the University entering into a transaction with the affected vendors. Questioned Costs: None noted. Repeat Finding: No. Recommendation: PwC recommends cross training of individuals responsible for the daily system interactions with the third-party servicer to ensure any system issues are promptly resolved and new vendors are checked for suspension and debarment prior to the University entering into a transaction with them. Management’s Views and Corrective Action Plan: Management’s response is included in Management's Views and Corrective Action Plan included at the end of this report after the Schedule of Status of Prior Audit Findings.

Congressional Grants – Suspension and Debarment: Information on Federal Program: U.S. Department of Housing and Urban Development Congressional Grant (Federal Assistance Listing Number 14.251). Criteria: 2 CFR Section 200.214 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the Organization is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The Organization did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214. Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.214. The Organization 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 Organization could be overpaying for goods and services. Questioned Costs: None. Perspective Information: As part of the required procurement testing, a review of the vendor charged to the Congressional grant and therefore represented purchases with federal dollars was performed. The vendor was not suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.214 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 responsible officials and planned corrective actions: The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025.

Congressional Grants – Suspension and Debarment: Information on Federal Program: U.S. Department of Housing and Urban Development Congressional Grant (Federal Assistance Listing Number 14.251). Criteria: 2 CFR Section 200.214 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the Organization is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The Organization did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214. Statement of Effect: The Organization is not in compliance with 2 CFR Section 200.214. The Organization 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 Organization could be overpaying for goods and services. Questioned Costs: None. Perspective Information: As part of the required procurement testing, a review of the vendor charged to the Congressional grant and therefore represented purchases with federal dollars was performed. The vendor was not suspended or debarred from participation in Federal assistance programs or activities. Recommendation: We recommend that the Organization review the requirements of 2 CFR Section 200.214 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 responsible officials and planned corrective actions: The Capital District YMCA reviewed the vendor used for our project when the auditors brought this to our attention and we did not find any suspension or disbarment information. We will incorporate this vendor review into our process for all programs or activities related to Federal contracts. This will be done in conjunction with the procurement policy and be in place by July 31, 2025.

Federal Program: 93.493 – Congressional Directives, U.S. Department of Health and Human Services, FAIN CE152180 passed through the Health Resources & Services Administration Criteria or Specific Requirement: Procurement, Suspension & Debarment, 2 CFR 200.320 Condition: The Company paid funds to a vendor that qualified under sole source procurement requirements. In the vendor’s contract with the Company, the vendor confirmed it was not suspended or debarred. The Company did not document its process for determining sole source procurement or document its search to confirm the vendor was not suspended or debarred. Cause: The Company does not have policies in place that comply with federal procurement, suspension and debarment requirements. Effect: The Company’s internal controls did not ensure proper documentation that the vendor materially complied with the federal procurement requirements. Questioned Costs: None Context: Federal procurement standards require entities that receive federal awards to have specific policies that comply with 2 CFR Section 200.318-320. The requirements specify that policies must establish thresholds and procedures for micro-purchases, simplified acquisitions, and formal purchases. When vendors are selected, federal funds are prohibited from going to certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards (2 CFR 200.214). The Company did not have policies in place to ensure compliance with these federal procurement guidelines. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: The Company has policies for vendor qualification in place surrounding critical vendors. We recommend considering all vendors that are awarded contracts to be paid with federal awards critical or otherwise amending the Company’s contracting review process or critical vendor policy to incorporate specific procedures when federal funds are used. These procedures should include a documented search of Sam.gov for suspension and debarment of the vendor. The Company should establish procurement thresholds and specific procedures for those thresholds as outlined in 2 CFR Section 200.318-320. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See attached corrective action plan.

Criteria: In accordance with 2 CFR §180 and §200.214, non-federal entities are prohibited from entering into covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Entities must verify that contractors and subcontractors are not excluded by checking the System for Award Management (SAM.gov) prior to awarding contracts funded by federal awards. Condition and Context: During our audit of procurement activities under the Health Center Infrastructure Support federal award, we identified multiple instances where the entity failed to verify the suspension and debarment status of vendors prior to awarding contracts exceeding the $25,000 threshold. Documentation of verification through SAM.gov or equivalent methods was not available for these transactions. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors being used on the project funded with federal awards. Effect: Failure to verify vendor eligibility increases the risk of awarding federal funds to ineligible parties, which may result in questioned costs, reputational harm, and potential disallowance of expenditures by the federal awarding agency. Cause: While the Center’s formal policies dictate that procedures will be followed to ensure the above criteria are met, staff responsible for procurement were unaware of the verification requirement or did not consistently apply it. Recommendation: We recommend the entity ensure that staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already-established policies that the Center has regarding such requirements. Staff involved in procurement should receive training on federal suspension and debarment requirements to ensure consistent compliance.

2025-004 Lack of Documentation for SAM.gov Exclusion Checks. Type: Material Weakness. Condition: The Village did not retain documentation to support that exclusion checks were performed on SAM.gov for vendors and subrecipients associated with the Water and Waste Disposal Systems For Rural Communities program. As a result, there is no evidence that the entity verified whether these parties were suspended or debarred prior to entering covered transactions. Criteria: Per 2 CFR 180.300 and 200.214 of the Uniform Guidance, non-federal entities must verify that contractors and subrecipients are not suspended or debarred before awarding federal funds. Acceptable methods include: - Checking the SAM.gov exclusion list, - Collecting a certification from the entity, - Including a clause in the contract or agreement. - Documentation of the verification process must be retained to demonstrate compliance. Cause: The entity did not have a formal process in place to ensure that SAM.gov checks were performed and documented prior to awarding federal funds. Effect: Without documented verification, there is a risk that federal funds could be awarded to ineligible parties, potentially resulting in noncompliance with federal regulations and exposure to questioned costs or future audit findings. Questioned Costs: n/a. Recommendation: We recommend that the Village implement and enforce procedures to: - Perform SAM.gov exclusion checks prior to awarding federal funds, - Retain screenshots or other documentation as evidence of the checks, - Train relevant staff on compliance requirements under Uniform Guidance. Views of Responsible Officials: Management concurs with the auditor’s finding regarding the lack of verification against the System for Award Management (SAM.gov) prior to entering into agreements with subrecipients and contractors under federal awards. We acknowledge that conducting these checks is a critical control to ensure compliance with federal regulations and to prevent engagement with suspended or debarred entities. The omission was due to a gap in our internal procedures, and we are taking immediate corrective action. Management is implementing a formal policy requiring SAM.gov verification for all applicable transactions, and staff will be trained on the updated procedures. We are also exploring automated solutions to ensure consistent documentation and compliance moving forward. We appreciate the auditor’s observation and remain committed to strengthening our internal controls and ensuring full compliance with Uniform Guidance requirements.

2025-005 Suspension and Debarment Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic problem Cause The Organization did not follow its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context Out of four covered transactions selected, only one included evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested by the auditor and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion check should be maintained as part of the supporting documentation for the expenditure. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

2025-005 Suspension and Debarment Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 & 93.527 Health Center Program Cluster Award Numbers H80CS00513, H8FCS41684 Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Title 2 CFR 200.214 and Title 2 CFR 180.300 require that organizations “verify that the person with whom you intend to do business is not excluded or disqualified” before entering into covered transaction (procurement contracts, purchase orders or agreements greater than or equal to $25,000) with persons or vendors. Condition The Organization entered into covered transactions without verification that vendors/contractors were not excluded from doing business with the federal government. This finding appears to be a systemic problem Cause The Organization did not follow its policy to verify that persons or entities contracted with were not listed on the exclusions list prior to entering into the contracts or purchase agreements. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context Out of four covered transactions selected, only one included evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested by the auditor and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that exclusion checks be performed prior to signing any contracts or purchase orders or agreements that are covered transactions. This exclusion check should be maintained as part of the supporting documentation for the expenditure. Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined below.

Finding 2024-001: Suspension and Debarment (Significant Deficiency) Information on the Federal Program: 93.048 Criteria: According to 2 CFR §200.30, the non-Federal entity (i.e. the Organization) 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 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 in the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is subject to 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. Condition: The Organization failed to perform and/or properly document its due diligence with respect to these requirements. Cause: The Organization experienced turnover during the year, resulting in inconsistency and oversight of the compliance requirement. Effect or Potential Effect: The Organization is exposed to an increased risk that future noncompliance could occur by entering into transactions with vendors, contractors, or consultants that are suspended and debarred. If a non-Federal entity knowingly does business with an excluded person, the agency responsible for the Center's funding may disallow costs, annul or terminate the transaction, issue a stop work order, debar or suspend the non-Federal entity, or take other remedies as appropriate. Questioned Costs: None noted. Context: During our audit, we noted two cases our of nine samples in which the Organization did not perform or did not maintain proper support to demonstrate that it performed checks via SAM.gov to ensure that potential vendors, contractors, or consultants are suspended or debarred. The failure to screen such parties increases the possibility that U.S. Government funds may inadvertently be provided to individuals or organizations deemed to be excluded by the U.S. Government. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend the Organization implement internal controls to ensure that all vendors, contractors, and consultants are screened for suspension and debarment prior to entering into any executed contract. We further recommend that a policy be formalized and implemented that requires an annual screening of any current vendors, contractors, or consultants as well.

Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Program: Continuation of the National Evaluations System for Health Technology Coordinating Center Assistance listing number: 93.103 Federal award identification number and year: • 2U01FD006292-06 2024 • 3U01FD006292-06S1 2023 Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Order 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. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition and context: The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed however the evidence of the search on sam.gov was not retained. A sample of five vendors with a total contract value of $8,528,526 was selected from a population of twelve. Cause: The Organization’s management did not retain evidence of compliance with the above criteria regarding suspension and debarment due to oversight. Effect: The Organization’s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management updates its policies and procedures to ensure adequate supporting documentation of suspension and debarment verification is maintained. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Program: Continuation of the National Evaluations System for Health Technology Coordinating Center Assistance listing number: 93.103 Federal award identification number and year: • 2U01FD006292-06 2024 • 3U01FD006292-06S1 2023 Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Order 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. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition and context: The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed however the evidence of the search on sam.gov was not retained. A sample of five vendors with a total contract value of $8,528,526 was selected from a population of twelve. Cause: The Organization’s management did not retain evidence of compliance with the above criteria regarding suspension and debarment due to oversight. Effect: The Organization’s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management updates its policies and procedures to ensure adequate supporting documentation of suspension and debarment verification is maintained. Views of Responsible Officials: Management agrees with the finding. See corrective action plan.

Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities 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. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.

Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities 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. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.

Assistance Listing, Federal Agency, and Program Name ALN 21.027, Department of Treasury, COVID 19 Coronavirus State and Local Fiscal Recovery Funds ALN 20.205, Department of Transportation, Highway Planning and Construction Federal Award Identification Number and Year ALN 21.027: 1505 0271, 2022 ALN 20.205: 24455, 2021 Pass through Entity ALN 21.027: Not applicable ALN 20.205: Colorado Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Per 2 CFR 200.214, nonfederal entities 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. Nonfederal entities may satisfy the criteria prescribed by 2 CFR part 180 by either checking SAM.gov exclusions, collecting a certification or adding a clause or condition to the covered transaction with the contracted party. Condition The Town could not provide evidence that it performed a check to verify its contractors were not suspended or debarred. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context The Town used each of its grants to procure services from one contractor and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into its contracts, respectively. Plante & Moran, PLLC reviewed the SAM.gov website, noting that the two vendors were not listed as suspended or disbarred. Cause and Effect The Town did not retain evidence to support that it had conducted the search for whether the contractors were suspended or debarred prior to entering into the contracts. The lack of control could result in the Town entering into contracts with contractors that are suspended or debarred. Subsequently, the Town did complete the search on SAM.gov and retained evidence to support that the contractors were not suspended of debarred, thereby creating no questioned costs. Recommendation We recommend the Town implement its controls as designed by retaining supporting documentation to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Town acknowledges the finding. The oversight was unintentional and occurred due to a lack of formalized procedures for verifying suspension and debarment status for all applicable federal contracts and subawards.

2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.

2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.

2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.

2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.

2024-003 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection and the basis for the contract price." Condition The Organization has a procurement policy in place; however, the Organization neglected to document their suspension and debarment verification process for one of four procurement transactions tested. The Organization is also required by the Washington State Department of Agriculture ("WSDA") to receive prior approval for any equipment purchase or equipment repairs over $5,000. One of the four transactions tested did not receive prior approval from WSDA to make the purchase. There was no documentation that could support approval was received from WSDA after the purchase had been made. Cause The Organization claimed the suspension and debarment check occurred prior to entering into the transaction but neglected to retain documentation. The Organization also did not properly follow its procurement policy, nor the policy required by WSDA, requiring prior approval for any equipment purchase or repair over $5,000. Effect Payments may have been made to suspended or debarred vendors and gone undetected by the Organization. The Organization could have also made an equipment purchase or equipment repair that would not be refunded by WSDA (the pass-through entity). Repeat Finding No. Auditor's Recommendation The Organization should ensure the employee responsible for conducting a suspension and debarment check is (1) aware of the necessity to document the verification was done and (2) capable of documenting the verification. The Organization should also reevaluate its internal controls over procurements with WSDA funding to ensure that the Organization is receiving approval from the WSDA prior to making the purchase. Employees tasked responsible for making procurement transactions should be educated on the proper procurement procedures. Management should be checking for the WSDA approval prior to signing off on cash disbursements for equipment purchases or equipment repairs.

Criteria or Specific Requirement – Per 2 CFR §180.300 and §200.214, non-federal entities are prohibited from entering into covered transactions (e.g., contracts or subawards expected to equal or exceed $25,000) with parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Conditions – Verification of SAMS.gov vendors was not performed. Context – During our testing of procurement, we sampled nine expenditures totaling $367,163. The total population of procurement expenditures charged to the program was $800,000. We noted that all nine selections of expenditures did not have SAMS.gov verification documentation. Cause – The Association did not have a formal process or checklist to ensure that vendors were checked against the SAM.gov exclusion list before contract award. Procurement staff were not trained on this requirement. Effect – Use of non-approved vendors could have occurred. However, as part our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website. Recommendation – We recommend the Association implement a formal policy and procedure to verify all vendors against SAM.gov for covered transactions exceeding $25,000. Staff responsible for federal procurement should be trained, and documentation of vendor status verification should be retained with procurement records. Views of Responsible Officials and Planned Corrective Actions – Procurement Policy was updated and documentation will be maintained to support vendor verification in the future.

Subject: 2024-002 Material Weakness – Procurement and Suspension and Debarment Noncompliance 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 – Procurement and Suspension and Debarment Noncompliance 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. Federal Award Findings and Questioned Costs (Continued) Condition and Context: The City lacked a formalized procedure for verifying suspension and debarment status for 1 covered transaction under revenue loss category for the CSLFRF award. This covered transaction paid for additional costs added onto the purchase of a fire engine with a change order related to increased manufacturing costs incurred as a result of the Coronavirus pandemic. The City did not verify suspension and debarment on this vendor prior to paying for these costs under CSLFRF. Without proper 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. Although no suspended or debarred vendors were identified in the sampled transactions, the lack of internal controls and documentation constitutes material noncompliance with 2 CFR §200.214. Cause and Effect: The City did not establish formal procedures on suspension and debarment requirements for one of the eleven covered transactions tested, resulting in material noncompliance with the suspension and debarment requirements of the CSLRF program and increased risk of using federal funds with ineligible vendors. Recommendation: We recommend the City develop and implement formal written procedures to ensure suspension and debarment checks are performed on all CSLFRF transactions and documented appropriately. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation and plans to implement corrective action by December 31, 2025. Staff are in the process of drafting internal policies for adoption by the appropriate boards to address this item as soon as possible for any of our grant funds not managed by a third-party administrator.

Criteria or Specific Requirements Per 2 CFR 200.214 Suspension and debarment, non-Federal entities are subject to the nonprocurement 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 excluded from or ineligible for participation in Federal assistance programs or activities. Per CFR 180.300, Subpart C: Responsibilities of Participants Regarding Transactions Doing Business With Other Persons, when an entity enters into a covered transaction with another person at the next lower tier, the entity must verify that the person with whom the entity intends to do business is not excluded or disqualified. The entity does 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. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-002. Per the CAP, the Foundation will conduct regular, ongoing monitoring of vendors providing services billed to grantors, including identifying all grant-reimbursed vendors and coordinating with Accounts Payable to perform annual suspension and debarment checks. We noted that the Foundation’s updated formal policies and procedures now require suspension and debarment checks at initial vendor setup and on an annual basis thereafter. Based on test work over a sample of 6 vendors covering the period from September 1, 2024 (CAP implementation date) to December 31, 2024, we did not identify any vendors in the sample who were suspended or debarred. However, we were unable to obtain documentation demonstrating that the Foundation performed the annual vendor suspension and debarment verification checks. Evidence that the annual vendor suspension and debarment verification checks had been performed was not yet available. Questioned Costs None. Cause and Effect For the period from September 1, 2024 (CAP implementation date) to December 31, 2024, the annual vendor suspension and debarment verification checks were still in progress, and supporting documentation was not yet available. The Foundation subsequently completed the annual checks in February 2025, which aligns with the typical start dates of most vendor contracts.