Findings Citing § 200.214

2026-001 Suspension and Debarment Program Information Federal Agency U.S. Department of Health and Human Services Assistance Listing Numbers 93.493 Congressionally Directives Award Numbers 1 CE2CS54401‐01‐00 Criteria 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. [ ] Compliance Finding [X ] Significant Deficiency [ ] Material Weakness Condition The Organization did not retain written evidence for its verification on SAM.gov for its Vendors. Cause The Organization did not follow its policy to document its verification 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 does not have evidence its covered transactions are not with persons who have been suspended or debarred. Questioned Costs None noted. Context We sampled one of three vendors used in covered transactions for which the Organization did not retain evidence that an exclusion check was performed prior to signing the contract. Exclusions checks were performed after documentation was requested, and no excluded vendors were identified. Recommendation We recommend the Organization implement controls requiring that evidence of exclusion checks be retained prior to signing any contracts or purchase orders or agreements that are covered transactions. Views of responsible officials and planned corrective action Management agrees with the auditor’s narrative associated with Finding 2026-001. It has consistently been the Organization’s policy to verify that vendors and contractors are not suspended or debarred by checking SAM.gov prior to engagement. However, management acknowledges that written verification/documentation of these checks was not formally retained in the project files prior to entering into contracts.

2026-002 Suspension and Debarment (repeat of finding 2025-004) Program Information Federal Organizations U.S Department of Agriculture (passed through California Department of Public Health) Assistance Listing Numbers 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Numbers 25-10160, 22-10237 A05 Criteria 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 transactions (procurement contracts, purchase orders, or agreements greater than or equal to $25,000) with persons or vendors. [ ] Compliance Finding [X] Significant Deficiency [ ] Material Weakness 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 issue. Cause The Organization did not maintain documentation evidencing its compliance with 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. Suspension and debarment check were performed, but not until after the prior year’s audit was completed and this issue was identified. Effect The Organization may have entered into covered transactions with persons who have been suspended or debarred. Questioned Costs None noted. Context We tested four vendors with “covered transactions” under assistance listing number 10.557. All vendor suspension and debarment checks were performed after the initial transaction had already been entered into, due to the timing of the transaction compared to the timing of the completion of the prior year’s audit. Recommendation We recommend the Organization perform vendor checks prior to entering into procurements meeting the covered transaction criteria and retain documentation that the checks were performed and when they were performed. In addition, we recommend that the Organization update these checks on an annual basis. Views of responsible officials and planned corrective action Management concurs with Finding 2026-002 and reports that the related corrective actions have been completed. The finding carried over from the prior audit period and has been resolved by management through implementation of the vendor verification and documentation procedures described in the corrective action outlined on page 39.

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

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

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

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

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

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

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

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

Environmental Protection Agency Direct Program: Congressionally Mandated Projects - 66.202 Award Year: 2023 Criteria or Specific Requirement - Suspension and Debarment In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. In accordance with 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for a vendor prior to entering into a contract. Cause: The BPU's controls to ensure suspension and debarment checks on vendors receiving federal funds did not operate effectively. Effect or Potential Effect: Federal funds could be paid to entities that are suspended or debarred. Questioned Costs - None Context: The BPU entered into a contract during the year ended December 31, 2025 that was considered a "covered transaction" and spent approximately $74,000 under this contract. This contract was selected for testing suspension and debarment and the BPU did not check the vendor's suspension and debarment status. Identification of Prior Year Finding: N/A Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with federal funds. Views of Responsible Official and Planned Corrective Action: Management agrees with finding. See corrective action plan.

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

FINDING 2025-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 1505-0271 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 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., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The City did not have policies or procedures in place to address the SLFRF suspension and debarment requirements. During the audit period, the City entered into one covered transaction totaling $860,000, which met the $25,000 threshold for verification. However, the City did not verify the vendor's suspension or debarment status prior to payment because no process existed to ensure contractors were not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 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." INDIANA STATE BOARD OF ACCOUNTS 16 CITY OF HUNTINGTON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The City was not aware of the suspension and debarment requirements associated with the SLFRF grant. Because the City does not typically receive large federal awards, it did not have formal policies or procedures in place to verify vendors' suspension and debarment status. The City hired a consultant to provide guidance related to a large reconstruction project and to assist with federal grant requirements; however, the City relied on this general guidance and did not establish its own process to ensure compliance with the suspension and debarment requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure contractors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay contractors who have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City establish and implement a formal system of internal controls to ensure compliance with suspension and debarment requirements. This should include developing and strengthening written policies and procedures to verify, prior to entering into a contract or making payments of $25,000 or more with federal funds, that contractors are not suspended, debarred, or otherwise excluded from participation in federal assistance programs. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding No. 2025-002: Subrecipient Monitoring and Procurement and Suspension and Debarment – Noncompliance Federal Program Name: Juvenile Mentoring Program Pass-through Entity: None Federal Assistance Listing Number: 16.726 Criteria Uniform Guidance requires that non-Federal entities ensure that they do not make subawards to entities that are suspended or debarred from participating in Federal programs. Recipients and subrecipients are subject to the non-procurement suspension and debarment regulations set forth in 2 CFR §200.214 and 2 CFR Part 180, which restrict the issuance of Federal awards and subawards to excluded parties. Condition During the audit period, the Partnership issued subawards to subrecipients; however, the Partnership’s current subrecipient policies are missing several critical elements, including procedures to verify that subrecipients are not suspended or debarred by the federal government, requirements to pass applicable federal special conditions down to subrecipient awards, methods to track the total amount of funding provided to subrecipients under each federal program, processes to ensure that payments to subrecipients minimize the time between the transfer of federal funds from the grantee and disbursement to the subrecipient, a risk-based monitoring approach, and an on-site monitoring process that includes reviews of financial and administrative aspects of the program, among other areas. Cause The Partnership had not previously developed or updated its subrecipient monitoring policies to fully align with the requirements of Uniform Guidance. Management relied on informal practices and staff knowledge rather than comprehensive, documented procedures to address suspension and debarment verification, subaward compliance requirements, cash management, and risk-based monitoring. In addition, limited compliance resources and the absence of a centralized compliance review process contributed to gaps in policy development and implementation during the audit period. Effect Without verification of suspension and debarment status, the Partnership is at risk of making subawards to entities that are ineligible to receive Federal funds. This could result in questioned costs, required repayment of Federal funds, or other sanctions imposed by the Federal awarding agency or pass-through entity. Questioned Costs None noted. Context Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR 200.318 through 200.327 and must follow the subrecipient monitoring and management standards set out at 2 CFR 200.331 through 200.333. They must use their own documented procurement and subrecipient monitoring procedures, which reflect applicable state and local laws and regulations, provided that the procurements and subawards conform to applicable federal statutes and the procurement and subrecipient monitoring requirements identified in 2 CFR Part 200. Recommendation We recommend that the Partnership implement written policies and procedures to ensure that all subrecipients are verified as not suspended or debarred prior to the execution of subawards. Acceptable methods of verification include reviewing SAM.gov exclusion listings, obtaining written certifications from subrecipients, or incorporating suspension and debarment representations into subaward agreements. Documentation of the verification should be retained in accordance with record retention requirements. Management’s Response/View of Responsible Officials Management agrees with this finding, see the Corrective Action Plan.

FINDING 2025-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2021 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 CITY OF AUBURN SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF), 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., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The City did not have any policies or procedures in place related to the SLFRF suspension and debarment requirements to determine whether each required vendor was suspended or debarred. Upon inquiry of the City, it was determined that there were two covered transactions paid with SLFRF during the audit. One was a contract that started in 2024 and had payments in both 2024 and 2025 totaling $2,267,000, and one that started in 2025 for $887,844. In testing the two transactions, it was noted that the City did not verify the suspension or debarment status for the vendor that started in 2025 prior to payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 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." 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." INDIANA STATE BOARD OF ACCOUNTS 14 CITY OF AUBURN SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The City was unable to provide documentation for one covered transaction that it properly verified a contractor was neither suspended nor debarred or otherwise excluded or disqualified from participating in federal assistance programs or activities. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure that contractors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs. Recommendation We recommended that management of the City design and implement a system of internal controls to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into contracts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

U.S Department of Health and Human Services Federal Financial Assistance Listing #93.493 Congressional Directives Procurement, Suspension & Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200. 303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contracts with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: The Hospital does not have an internal control policy in place to ensure covered transactions are with vendors that are not suspended or debarred, and no evidence was retained regarding ensuring the vendor was not suspended or debarred. Cause: The Hospital does not have an internal control policy or procedures to ensure compliance and was not aware of options available for monitoring to ensure compliance. Effect: The Hospital may enter into a covered transaction with a vendor that is suspended or debarred. Questioned Costs: None reported. Context: A nonstatistical sample of 3 out of 13 covered transactions were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital update their procurement policy to ensure it includes suspension and debarment requirements. Additionally, we recommend management complete a review to ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into a procurement transaction and retain documentation to support that these procedures are being performed. Views of Responsible Officials: Management agrees with the finding.

2025-005 Lack of Documentation for SAM.gov Exclusion Checks Type: Material Weakness Condition: The Organization did not retain documentation to support that exclusion checks were performed on SAM.gov for vendors and subrecipients associated with the Community Resilience Hubs for Detroit Neighborhoods 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 Organization 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 Organization 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.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Assistance Listing Number: 93.318 Federal Award Identification Number and Year: NU3HCK000011/2021 Award Period: 1/1/2025 – 12/31/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: In accordance with 2 CFR §200.214 and 2 CFR Part 180, nonfederal entities are prohibited from entering into covered transactions with suspended or debarred parties. The OMB Compliance Supplement requires the entity to establish and maintain internal controls to ensure compliance with suspension and debarment requirements. Condition: During testing, we noted the Society performed suspension and debarment evaluations on vendors (e.g., SAM.gov verification), however did not retain documentation demonstrating that these vendor evaluations were completed prior to contract execution. Questioned costs: None. Context: Documentation reviewed lacked sufficient date and time stamping to evidence when the evaluation was performed. This condition was identified for all items tested; however, we independently verified that the vendors selected were not suspended or debarred. Cause: The Society did not maintain adequate documentation to support that suspension and debarment procedures were performed timely. Effect: Although no instances of noncompliance were identified, the lack of documented evidence supporting the timely performance of suspension and debarment procedures increases the risk that the Society could enter into transactions with ineligible parties. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Society enhance controls to ensure adequate documentation is retained to support the procedures are performed timely with respect to vendor evaluation for suspension or debarment. Views of responsible officials: There is no disagreement with the audit finding. Management has developed a corrective action plan to address the matter identified which is presented in the accompanying Corrective Action Plan.

Finding 2025-001 Internal control deficiency and noncompliance over procurement and suspension and debarment and special tests and provisions. Identification of the federal program: Assistance Listing Number 93.493: • Congressional Directives • U.S. Department of Health and Human Services • Federal award identification number – CE147096 • Federal award year – September 1, 2022 to August 31, 2025 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 Internal controls. 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). Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 General procurement standards (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; (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders; (c) (1) the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 General procurement standards (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. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.319 Competition (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and 200.320. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 Methods of procurement to be followed. 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) (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; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price; (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 Methods of procurement to be followed. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.324 Contract cost and price. (a) The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Title 2, Subtitle A, Chapter I, Part 180, Subpart C 180.300 What must I do before I enter into a covered transaction with another person at the next lower tier? 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; (b) Collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. The Health Resources and Services Administration (HRSA) project guidance requires the following: • Federal Interest – Real Property – For all construction projects, regardless of award amount, you are required to file a Notice of Federal Interest (NFI). The NFI requires prior written approval in order for the property owner to mortgage, sell, transfer, or use the property for a purpose inconsistent with the award. A notarized NFI must be filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and once filed, a copy must be provided to the appropriate HRSA Grants Management Specialist. Condition: During our testing over procurement, we observed management did not have documented procurement procedures that conformed to the procurement standards identified in 2 CFR section 200.318 to 200.327 and written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Management did not have internal controls in place over small purchase procurements to ensure price or rate quotations were obtained from an adequate number of qualified sources, formal procurements to ensure sealed bids or proposals were obtained through public advertising, and completion of a cost or price analysis in connection with all procurement actions exceeding the simplified acquisition threshold. Management did not maintain records for procurements to document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. During our testing over suspension and debarment, we observed management did not have documented suspension and debarment procedures and did not have internal controls in place to ensure vendors were searched for suspension and debarment at the time of vendor selection. During our testing over special tests and provisions, we observed management did not file an NFI against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and provide to the appropriate HRSA Grants Management Specialist. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or potential effect: Procurements were not supported by internal controls and could potentially include unreasonable prices or rates. In addition, if a search for suspension and debarment is not conducted, the entity could contract with vendors that are suspended or debarred. Special tests and provisions were not supported by internal controls in that an NFI was not filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located. Questioned costs: $1,154,000 – Assistance Listing Number 93.493 – Congressional Directives – Federal award identification number – CE147096 Questioned costs were computed as the entire population of procurement transactions subject to small purchase, formal procurement, suspension and debarment, and special tests and provisions compliance requirements. Questioned costs means a cost that is questioned by the auditor because of an audit finding: (1) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds or (2) where the costs, at the time of the audit, are not supported by adequate documentation. Context: During our testing over procurements, we obtained a listing of expenditures that included $1,154,000 of procurement transactions subject to small purchase, formal procurement, suspension and debarment, and special tests and provisions compliance requirements. We observed management did not have internal controls in place to ensure the compliance requirements as stated in the criteria or specific requirement section above were performed. Identification as a repeat finding, if applicable: No. Recommendation: Management should create documented procurement procedures that conform to the procurement standards identified in 2 CFR section 200.318 through 200.327 and written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Management should develop and implement internal controls over small purchase procurements to ensure price or rate quotations are obtained from an adequate number of qualified sources, formal procurements to ensure sealed bids or proposals are obtained through public advertising, and completion of a cost or price analysis in connection with all procurement actions exceeding the simplified acquisition threshold. Management should maintain records for procurements to document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Management should create documented suspension and debarment procedures and develop and implement internal controls to ensure vendors were searched for suspension and debarment at the time of vendor selection. Management should review the procurements identified as questioned costs to identify if any improper payments were made to the entity. Management should develop and implement internal controls over special tests and procedures to ensure that an NFI is filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and provide to the appropriate HRSA Grants Management Specialist. Views of responsible officials: We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist.

FINDING 2025‐002 – Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Assistance Listing Number: 21.029 Federal Program Name: COVID-19 - Coronavirus Capital Projects Fund Award Year: 2024 Criteria: Uniform Guidance requires non-federal entities to establish and adhere to documented procurement procedures and ensure compliance with suspension and debarment requirements. 2 CFR §200.318(a): Requires entities to have and use documented procurement procedures consistent with federal standards. 2 CFR §200.318(i): Requires maintenance of records sufficient to detail the history of procurement. 2 CFR §200.214: Prohibits contracting with parties that are suspended or debarred, requiring verification. Condition and context: The Cooperative has not developed or implemented formal written procurement policies and procedures that comply with Uniform Guidance requirements. Additionally, the Cooperative has not established procedures to ensure compliance with suspension and debarment requirements. As a result, for a sample of two vendors and nine procurement transactions tested, the Cooperative did not document suspension and debarment verification (e.g., SAM.gov) for vendors and contractors procured under the federal award. The absence of documented procedures also indicates that procurement activities are not being performed under a standardized framework aligned with federal requirements. Questioned costs: None. Effect: Due to the lack of formalized procurement processes and controls there is an increased risk of noncompliance with federal procurement standards. Expenditures could be paid to suspended or debarred vendors resulting in disallowed expenditures, and noncompliance with the grant agreement. Cause: Management did not have a sufficient understanding of the procurement-related control requirements necessary to comply with the grant agreement and Uniform Guidance. As a result, procurement processes were not formally established or aligned with federal requirements. Repeat finding: Yes. Recommendation: We recommend the Cooperative develops and implements written procurement policies and procedures in compliance with 2 CFR §200.318–§200.327, including competitive procurement requirements, cost/price analysis, documentation, and record retention. Establish procedures to ensure compliance with suspension and debarment requirements, including performing SAM.gov verification prior to contract award and retaining documentation of verification in procurement files. Lastly, we recommend implementing monitoring controls to ensure procurement documentation and compliance requirements are consistently met. Views of responsible officials and planned corrective actions: Wabash currently maintains the process of procurement standards and internal controls. While we previously managed contractor selections through established internal practices, we recognize the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash implemented a formal Procurement Policy and Procedure June 30, 2026. Contact Person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Emergency Solutions Grant Assistance Listing Number: 14.231 Award Period: January 1, 2025 to December 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR §200.318(a) and §200.318(d), non-federal entities are required to maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts, and must follow documented procurement procedures that promote full and open competition. Additionally, 2 CFR §200.320 requires entities to use appropriate procurement methods based on the nature and size of each procurement and to perform cost or price analysis as applicable. Further, pursuant to 2 CFR §200.214, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred and are required to verify the eligibility of vendors (e.g., through the System for Award Management (SAM)) prior to entering into transactions and periodically as appropriate. These requirements imply the need for ongoing evaluation and documentation of procurement decisions, vendor eligibility, and compliance, particularly when procurements span multiple funding periods or awards. Condition: During our review, we noted that the organization performed procurement procedures, including vendor selection, cost/price evaluation, and suspension and debarment verification, at the time of initial engagement with a vendor. However, the organization did not subsequently review, monitor, or reperform procurement procedures—including periodic suspension and debarment checks—in later years, despite continued use of the vendor across different grant awards and grant periods. Questioned Costs: None Context: The organization engages vendors to provide goods and services supported by multiple grant awards over varying grant periods. Procurement requirements, including verification that vendors are not suspended or debarred, apply at the time of vendor selection and should be periodically reassessed to ensure continued compliance with applicable regulations, particularly when funding sources, grant terms, or procurement thresholds change. Cause: This condition appears to be the result of a lack of formal policies or controls requiring periodic reassessment of vendor selection, including suspension and debarment verification, as well as insufficient awareness of ongoing procurement and eligibility requirements under federal regulations. Effect or Potential Effect of Finding: Failure to reassess procurement decisions, monitor vendor relationships, and reverify suspension and debarment status across grant periods increases the risk of noncompliance with federal procurement standards. This includes the risk of contracting with ineligible vendors, inadequate competition, or unsupported pricing. Such noncompliance may result in questioned costs, disallowed expenditures, repayment of grant funds, and increased exposure to vendor performance and compliance risks. Repeat Finding: No. Recommendation: We recommend that management implement formal procurement policies requiring periodic reassessment of vendors used in federally funded programs, particularly when new grant awards are received or grant periods change. This should include evaluating whether the original procurement method remains appropriate, performing updated cost or price analyses as necessary, and conducting and documenting periodic suspension and debarment checks (e.g., SAM verification). Additionally, management should establish oversight controls to ensure procurement compliance and vendor eligibility are maintained throughout the lifecycle of vendor relationships in accordance with 2 CFR §200.318–200.320 and §200.214. Views of Responsible Official: There is no disagreement with the audit finding.

FINDING 2025-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SLT-9293 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF), 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., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During the audit period, the City paid a contractor $1,875,887 with the SLFRF funds for the Steury Avenue and Lincoln Avenue Reconstruction and Drainage Improvements project, which met the $25,000 threshold for suspension and debarment verification. However, the City did not believe the contract with the vendor required the Procurement and Suspension and Debarment compliance requirement. As such, the City did not verify the contractor's suspension or debarment status prior to payment to ensure contractors were not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 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." INDIANA STATE BOARD OF ACCOUNTS 16 CITY OF GOSHEN SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The City had not designed or implemented effective policies and procedures to verify that vendors were not suspended or debarred or otherwise excluded from participating in federal programs prior to entering into covered transactions using the SLFRF funds. While an internal control process was in place, it did not ensure that all vendors were not suspended or debarred from receipt of federal grant funds for goods and services. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure contractors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay contractors who have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City establish and implement a formal system of internal controls to ensure compliance with the suspension and debarment requirements. This should include developing and strengthening written policies and procedures to verify, prior to entering into a contract or making payments of $25,000 or more with federal funds, that contractors are not suspended, debarred, or otherwise excluded from participation in federal assistance programs. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding: 2025-002 Procurement, Suspension and Debarment Federal Agency(ies): United States Department of Defense Federal Program(s): Research and Development Cluster Assistance Listing Number(s): 12.300, 12.330 Pass-through Entity (if applicable): Direct awards and pass-through awards from RTI International and Greensight, Inc. Award Identification Number and Year: Various Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR 200.317 through 2 CFR 200.327, non-Federal entities are required to maintain documentation sufficient to detail the history of procurement transactions. Such documentation should include, as applicable, the rationale for the method of procurement, contractor selection, basis for contract price, and the basis for any sole-source procurement. Additionally, pursuant to 2 CFR 180 and 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred and should maintain documentation demonstrating that applicable vendors were screened prior to contracting or payment. Condition: As part of our testing of vendor expenditures charged to Federal awards within the Research and Development Cluster, we selected a statistical sample of procurement transactions and noted deficiencies in RoboNation's procurement and suspension and debarment documentation. Specifically, we noted instances in which RoboNation did not consistently document the rationale supporting its selection of vendors charged to Federal awards. In addition, for procurements utilizing a sole-source or noncompetitive procurement methodology, RoboNation did not consistently document which of the allowable exceptions under 2 CFR 200.320 justified the use of noncompetitive procurement. With respect to suspension and debarment requirements, we noted that RoboNation did not consistently maintain evidence that vendors were screened against the System for Award Management (SAM.gov) database prior to contracting or payment. We also identified instances in which SAM.gov screening reports were either undated or dated after execution of the vendor agreement and related payment activity. Cause: RoboNation's policies and procedures for procurement documentation and suspension and debarment compliance were not operating effectively. Specifically, controls were not sufficient to ensure that procurement files contained required support for vendor selection and sole-source procurements, nor were controls adequate to ensure that SAM.gov screenings were completed and documented prior to engaging vendors charged to Federal awards. Effect or Potential Effect: The lack of adequate procurement and suspension and debarment documentation increases the risk that procurement transactions may not comply with Uniform Guidance requirements and that vendors could be selected without sufficient support for the procurement method utilized. Additionally, the lack of timely and documented SAM.gov screenings increases the risk that Federal funds could be expended on vendors that are suspended or debarred from participation in Federally funded programs. Questioned Costs: $437,591 Context: As part of our testing of the Procurement, Suspension, and Debarment compliance requirements for the Research and Development Cluster, we selected a statistical sample of vendor transactions charged to Federal awards during the year ended December 31, 2025. Identification as a Repeat Finding, if Applicable: Yes, repeat of 2024-003. Recommendation: We recommend that management strengthen controls over procurement and suspension and debarment compliance by implementing procedures requiring procurement files to contain documentation supporting vendor selection, the procurement method utilized, and, when applicable, the specific basis for sole-source procurement under Uniform Guidance. In addition, management should establish procedures to ensure that SAM.gov screenings are performed and documented prior to contract execution or payment and that evidence of such screenings is retained within the procurement file.

Finding No. 2025-002 – Review of Vendors for Suspension or Debarment Federal CFDA No. and Program: 66.468 – Drinking Water State Revolving Fund Pass-through Agency: WI DOA Award Number: 45211 Criteria: 2 CFR §200.214 restricts recipients and subrecipients of federal awards from awarding contracts with parties that are debarred, suspended, or otherwise excluded from participating in federal awards. The City should transact with vendors who are not suspended or debarred. Condition/Context: The City does not have a control or process to review vendors to verify they are not suspended or debarred. For this program, two vendors were awarded contracts. During testing, it was noted that the City did not have documentation of the search for suspension or debarment of either vendor. The sample was not a statistically valid sample. Questioned Costs: Unknown Effect: The City could transact with vendors who are suspended or debarred. Recommendation: We recommend that the City review vendors for suspension and debarment during the contracting process and periodically thereafter.

Finding 2025-001 – Inadequate Documentation Supporting Compliance with Federal Procurement Requirements Federal Agency: U.S. Department of Treasury passed through Kansas Department of Commerce Federal Program: COVID-19, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal award identification number and year: SLFRP0140 - 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Pursuant to 2 CFR §§ 200.214, 200.319, and 200.327, non-Federal entities are required to verify that covered parties are not suspended or debarred from participation in Federal programs, conduct procurements in a manner providing full and open competition, and include applicable Federal award provisions in contracts funded by Federal awards. Condition: During testing of procurement contracts, we noted the following exceptions: • Certain contracts did not contain the applicable Federal contract provisions required by Appendix II to 2 CFR Part 200. Management indicated that the omission of the required provisions was identified through monitoring performed by the grant administrator acting on behalf of the pass-through entity and efforts were subsequently initiated to amend the affected contracts. • One contract below the questioned cost threshold lacked documentation demonstrating the procurement was conducted in a manner providing full and open competition. • One contract lacked documentation supporting the required price/cost analysis. • One contract lacked documentation evidencing performance of suspension and debarment verification procedures. Consequently, the Organization lacks controls to demonstrate compliance with certain Federal procurement requirements. Context: The exceptions identified above affected six contracts, representing approximately 17% of the procurement expenditures tested within the Procurement, Suspension, and Debarment compliance requirement. Based on audit procedures performed, the related expenditures were determined to be allowable costs, supported by appropriate documentation, and incurred in furtherance of the grant's objectives. Cause: The Organization did not maintain effective controls to demonstrate compliance with Federal procurement requirements. Effect: The Organization could not demonstrate compliance with certain Federal procurement requirements related to contract provisions, competition, and suspension and debarment. Questioned costs: None noted. Recommendation: We recommend the Organization implement procedures to ensure Federal procurement requirements, including contract provisions, competition requirements, and suspension and debarment verification, are performed, documented, and retained for all covered procurements. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Federal Award Identification Numbers and Years: 202525S252047 - 2025; 202626S26197 - 2025; 202626S262047 - 2025 Award Period: 10/1/24 - 9/30/25; 10/1/25 - 9/30/26 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance Criteria or specific requirement: In accordance with 2 CFR 200.318(a), non-Federal entities must maintain and follow documented procurement procedures that are consistent with applicable Federal statutes, regulations, and the terms and conditions of Federal awards. Additionally, 2 CFR 200.319(a) requires procurement transactions to be conducted in a manner providing full and open competition and supported by adequate documentation of the procurement process. Further, 2 CFR Part 180 and 2 CFR 200.214 prohibit non-Federal entities from entering into covered transactions with parties that are suspended or debarred and require verification that contractors are not suspended, debarred, or otherwise excluded from participation in Federal programs. These requirements were applicable to both the Department of Labor (CDL) and Department of Agriculture (BFET) major programs. Condition: During testing of the Procurement, Suspension, and Debarment compliance requirement for the Department of Labor (CDL) and Department of Agriculture (BFET) major programs, instances of noncompliance with federal procurement requirements were identified. Specifically, procurement files lacked required documentation demonstrating compliance with the organization's procurement procedures, including evidence of competition and Executive Director approval of vendor selections. In addition, procurement and vendor files lacked documentation supporting that suspension and debarment reviews were performed prior to entering into contracts with vendors. As a result, ANEW did not comply with federal Procurement, Suspension, and Debarment requirements applicable to the CDL and BFET major programs. Exceptions were identified in 2 of 4 procurement transactions and 3 of 3 suspension and debarment reviews tested for the Department of Labor program, and in 2 of 3 procurement transactions and 1 of 1 suspension and debarment review tested for the BFET program. In addition, the organization's procurement policy did not fully address all Uniform Guidance procurement requirements Questioned costs: None - despite insufficient documentation, all procured vendors tested were deemed to be reasonable for the program needs, and none were suspended or debarred, based on subsequent review. Context: ANEW expended federal funds under the Department of Labor (CDL) and Department of Agriculture Basic Food Employment and Training (BFET) programs, both of which are subject to Federal Procurement, Suspension, and Debarment requirements. As part of our compliance testing, we selected four procurement purchases under the CDL program and three procurement purchases under the BFET program. Of the four CDL procurement purchases tested, two lacked documentation evidencing Executive Director approval in accordance with the organization's procurement procedures. Of the three BFET procurement purchases tested, two lacked documentation evidencing Executive Director approval. In addition, we selected three vendors under each major program for suspension and debarment testing. For all 4 vendors tested across the CDL (3) and BFET (1) programs, management was unable to provide documentation demonstrating that required suspension and debarment reviews had been performed prior to entering into contracts with the vendors. In addition, the organization's procurement policy did not fully incorporate all Uniform Guidance procurement requirements, including requirements related to suspension and debarment procedures. Cause: Management's procurement policy was not fully aligned with Uniform Guidance procurement requirements and did not adequately address all required Federal procurement procedures. In addition, management did not consistently perform and retain documentation supporting procurement approvals and suspension and debarment reviews in accordance with Federal requirements and organizational policies. Effect: ANEW was unable to demonstrate compliance with certain Federal Procurement, Suspension, and Debarment requirements applicable to the CDL and BFET programs. As a result, the organization was exposed to an increased risk of entering into covered transactions with suspended or debarred vendors and of awarding procurements that were not supported by adequate competition or required approvals. Repeat Finding: No; this is the entity’s first single audit. Recommendation: We recommend management revise procurement policies to fully align with Uniform Guidance requirements and strengthen procedures to ensure procurement decisions, management approvals, competitive procurement documentation, and suspension and debarment verifications are consistently performed, documented, and retained. Views of responsible officials: There is no disagreement with the audit finding.

FINDING 2025-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2025 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 2024-004. Condition and Context An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 20 SHELBY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Suspension and Debarment Prior to entering into subawards and covered transactions with the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF), 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., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County did not have internal controls in place to ensure compliance with the suspension and debarment compliance requirement. Upon inquiry of the County's policies and procedures related to suspension and debarment requirements, the County stated that they did not have policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Five covered transactions for goods or services that equaled or exceeded $25,000 that were paid from the SLFRF funds during the audit period were identified. Each transaction was examined to determine whether the County verified the suspension and debarment status of the vendors prior to payment. The five covered transactions totaling $230,598 did not include the appropriate provisions in the contracts nor did the County require a certification or check the EPLS to ensure the entity was not suspended or debarred prior to making payment. 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 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. 31 CFR 19.300 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: INDIANA STATE BOARD OF ACCOUNTS 21 SHELBY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the County. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. 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 and subrecipients to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2025-002 Assistance Listing Number(s): 81.135 Name of Federal Program or Cluster: Research and Development Cluster Name of Federal Agency: Department of Energy Federal Award Identification Number: DE-AR0001838 Federal Award Year: 2024 Award Period: March 26, 2024 through September 25, 2025 Criteria or Specific Requirement: 2 CFR §200.214 requires non-Federal entities to comply with 2 CFR Part 180 regarding suspension and debarment. Under 2 CFR §180.300, non-Federal entities must not enter into a covered transaction with a party that is suspended, debarred, or otherwise excluded from participation in Federal programs. The requirements contemplate verification of eligibility before entering into a covered transaction. Documentation supporting the verification should be retained in accordance with the Federal award's applicable record-retention requirements. Condition: Convergent Research did not document that suspension and debarment verification was performed prior to entering into covered transactions. Based on inquiry with management and review of the procurement files, Convergent Research did not perform or retain evidence of a SAM.gov exclusion verification before entering into agreements. Subsequent SAM.gov searches were performed during the audit, and did not identify the vendors as currently excluded. Cause: Management indicated that suspension and debarment verification was not incorporated into the procurement process at the time the agreements were executed. Consequently, the procurement files did not contain contemporaneous evidence demonstrating that the vendors' exclusion status had been verified before award. Effect or Potential Effect: Because Convergent Research did not document the required pre-award verification, it could not demonstrate from its procurement records that it had complied with the suspension and debarment requirements applicable to these covered transactions at the time of award. Although subsequent SAM.gov searches did not identify current exclusions, those searches occurred after the respective agreements were executed and therefore do not establish that the required verification was performed before the transactions were entered into. We did not identify evidence that covered transactions were actually suspended, debarred, or otherwise excluded at the time of award. Accordingly, the finding relates to the absence of documented verification, rather than evidence that Convergent Research entered into a covered transaction with an excluded party. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that Convergent Research strengthen its procurement controls to require documented suspension and debarment verification before execution of all applicable covered transactions. The documentation should identify the vendor, date of verification, source used to perform the verification, and result of the search and should be retained in the procurement file. Views of Responsible Officials: Management agrees with the auditor’s recommendation and has incorporated required suspension and debarment verification into its federal grant procurement workflow, with documentation retained in the procurement file.

Finding 2025-003 I. Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Agriculture, Department of Defense, National Aeronautics and Space Administration, Promotion of the Arts Grants to Organizations and Individuals, National Science Foundation, Department of Veteran Affairs, Environmental Protection Agency, Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No.: Various Criteria or Specific Requirement: 2 CFR 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities under 2 CFR 180. 2 CFR 180.300 further states that non-federal entities are responsible for verifying the eligibility of vendors and contractors prior to entering into covered transactions. Condition: Management was unable to provide evidence of a control being consistently performed throughout the entire audit period to address the risk that the System may enter into a transaction with an entity that is suspended, debarred, or otherwise excluded, due to the timing of the implementation of the prior year corrective action plan. We noted the following matters during our testing of suspension and debarment: (a) The System did not obtain a detailed listing of all vendors screened with related results from its third-party service provider. The System received a summarized results report with the total number of vendors screened for suspension and debarment by the third-party service provider. However, a reconciliation was not performed and retained between the vendors provided by the System and the service provider’s summarized results report to evidence that all vendors submitted were screened. (b) The System did not retain evidence of review of the results provided by the third-party service provider, including evidence that unverified vendors or those that were indicated as excluded were investigated and evaluated by the System. (c) The System did not retain evidence of review of new vendors being screened for suspension and debarment prior to entering into a transaction. Cause: The System did not have a process in place for the entire year to review the results of screened vendors to verify that all vendors are screened. Effect or Potential Effect: The lack of effective controls over suspension and debarment has the potential to result in noncompliance with the requirement. By not performing a reconciliation between the listings submitted by the System and the results provided by the third-party service provider, there is a risk that vendors are not screened by the third-party service provider and such vendors used for federally funded activities may be suspended or debarred. Questioned Costs: None identified. Context: Management was unable to provide evidence of a control being consistently performed throughout the entire audit period, as described in the Condition section above. Identification as a repeat finding, if applicable: Yes. Prior year finding 2024-008 Recommendation: Management should enhance the design of the System’s controls related to the screening of new vendors prior to entering into transactions, as well as the on-going monitoring and screening of its vendors for suspension and debarment. In addition, management should perform and retain documentation to support reconciliation of the vendor list submitted to the third-party service provider and the results obtained to support that the screening process is completed for all vendors and that no suspended or debarred vendors are utilized by the System prior to entering into transactions. Views of Responsible Officials: Mount Sinai has taken corrective actions to address this issue which were completed by December 31, 2025. During 2025, the Health System created a process to ensure a vendor is not considered suspended or debarred. All existing vendors in the vendor master file, as well as all newly onboarded vendors through our credentialing process, are screened monthly through our designated sanction screening provider. In addition, we have implemented a new monthly manual control to review, confirm, and reconcile our vendor master against the files submitted to our sanction-screening provider. Our Internal Audit team also performs periodic, independent sanction screening checks on a sample of vendors to validate the accuracy and completeness of the third party screening results.

SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Spokane Conservation District January 1, 2025 through December 31, 2025 2025-001 The District did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring and suspension and debarment requirements, and it did not comply with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.727 Inflation Reduction Act Urban & Community Forestry Program Federal Grantor Name: U.S. Department of Agriculture Federal Award/Contract Number: 24-DG-11062765-154 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2024-001 Background During fiscal year 2025, the District spent $774,900 in federal funds from the Inflation Reduction Act Urban & Community Forestry Program. The objective of this program is to plan for, establish, manage and protect trees, forests, green spaces and related natural resources in and near cities and towns. Of this amount, the District passed through $260,472 to two subrecipients. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Subrecipient Monitoring When the District passes on federal funds to subrecipients, federal regulations require it to monitor subrecipient activities. This includes ensuring the subrecipient receives a federal single audit when required, following up and ensuring the subrecipient takes timely and appropriate action on all audit findings, and issuing a management decision as required. The District must maintain documentation showing it performed this verification. Suspension and Debarment Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the District enters into contracts or purchases goods and services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors are not suspended, debarred or otherwise excluded from participating in federal programs. The District may verify this by obtaining a written certification from the contractor, adding a clause or condition into the contract that states the contractor is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The District must verify this before entering into the contract, and must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Subrecipient Monitoring The District did not have effective internal controls to document and demonstrate it verified the two subrecipients tested received a single audit and that it followed up with the results of that audit, when necessary, as federal regulations require. We consider this internal control deficiency to be a significant deficiency. Suspension and Debarment Our audit found the District did not have adequate internal controls to verify the one contractor we tested that it paid more than $25,000 in federal funds was not suspended or debarred from participating in federal programs before purchasing from them. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Subrecipient Monitoring Although District staff said they were aware of the requirement and reviewed the Federal Audit Clearinghouse site, they could not locate documentation showing they verified whether the subrecipients received a single audit when required. Suspension and Debarment Although District staff said they were aware of the requirements, they could not locate documentation to show they verified the contractor’s suspension and debarment status. Additionally, although the District subsequently verified the contractor’s status when it received the prior audit finding for the 2024 audit, it was after purchasing from the contractor. Effect of Condition Subrecipient Monitoring The District did not retain documentation showing it verified whether the subrecipients received a single audit when required. Without documentation, the District cannot demonstrate it is properly monitoring its subrecipients and that the subrecipients complied with federal program requirements and received a single audit when required. Suspension and Debarment The District did not obtain a written certification from the contractor, insert a clause into the contract or check for exclusion records at SAM.gov to verify the contractor it paid $185,998 with federal funds was not suspended or debarred before contracting. Without adequate internal controls, the District increases its risk of awarding federal funds to contractors that are excluded from participating in federal programs. Any payments the District made to an ineligible party would be unallowable, and the awarding agency could potentially recover them. The District subsequently verified the contractor was not suspended or debarred. Therefore, we are not questioning costs. Recommendation Subrecipient Monitoring We recommend the District establish internal controls to retain documentation showing it verified that subrecipients received a single audit when required. Suspension and Debarment We recommend the District strengthen its internal controls to verify all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs and maintain documentation demonstrating compliance with this requirement. District’s Response The District concurs with Finding 2025-001. The District acknowledges that although staff performed searches of the Federal Audit Clearinghouse for both subrecipients and were aware of the suspension and debarment requirements; however, the District did not retain documentation demonstrating these verifications, as required by 2 CFR 200.303, 2 CFR 200.332, and 2 CFR 200.214. Subrecipient Monitoring District staff were aware of the single audit requirements and reviewed the Federal Audit Clearinghouse for both subrecipients during the audit period; however, documentation of those verifications was not retained. The District has since followed up in writing with both subrecipients and obtained written confirmation that neither subrecipient exceeded $1,000,000 in federal expenditures during fiscal year 2025 and that neither expects to exceed the single audit threshold in fiscal year 2026. Accordingly, single audits were not required for either subrecipient. The written correspondence is retained in the subaward files. Going forward, all subrecipient monitoring activities — including Federal Audit Clearinghouse searches, single audit determinations, follow-up on audit findings, and management decisions — will be documented and retained in each subaward file at the time the verification is performed. Suspension and Debarment The District concurs that documentation was not retained for the suspension and debarment verification of the contractor paid $185,998 in federal funds. The contractor was subsequently verified as not suspended or debarred, and no further contracting activity occurred under the affected award. The District has implemented controls requiring verification of suspension and debarment status — through a SAM.gov exclusion check, a written certification from the contractor, or a contract clause — before entering into any contract or purchase expected to equal or exceed $25,000, paid in whole or in part with federal funds, consistent with 2 CFR 200.214 and 2 CFR Part 180. Documentation of each verification will be retained in the procurement file at the time of award. Corrective Action To provide sustained assurance and to address both components of this finding, the District is implementing a project management system with automated reminders and checklists covering the full life cycle of federal awards, subawards, and procurements. In addition, the district has updated its suspension and debarment policy and will formalize subrecipient monitoring documentation requirements. These updates will be incorporated into the District's annual contract and procurement training for all relevant staff. Completion is anticipated by December 31, 2026. Auditor’s Remarks We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review corrective action taken during the next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303 Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 332, Requirements for passthrough entities, establishes subrecipient monitoring and management requirements for pass-through entities. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.

Department of Energy and Passed through Nebraska Department of Environment and Energy Federal Financial Assistance Listing 81.254, 2025-150224869 Grid Infrastructure Deployment and Resilience Procurement, Suspension & Debarment Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards in sections 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are applicable. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contract with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: Testing of expenditures under the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: -The District has not formalized and adopted a written procurement policy. - In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. - In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for vendor selection. Cause: Covered transactions were not evaluated compared to Uniform Guidance as it relates to procurement methods and suspension and debarment. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the District would be noncompliant with the compliance requirements outlined above. Additionally, the District may enter into a covered transaction with a vendor that is suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 2 out of 5 vendors were selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the District implement a procurement policy that complies with Uniform Guidance. In addition, we suggest that management implement procedures and control processes related to the review of covered transactions to ensure the procurement methods are being followed and any contracts include the required Uniform Guidance provisions. Also, management should ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into work with the vendor. Views of Responsible Officials: Management agrees with the finding.

FINDING 2025-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Auditor's Response The Town acknowledged in its Corrective Action Plan that one vendor paid with SLFRF funds was not verified for suspension and debarment status. Regardless of the timing of the prior audit engagement, the Town remains responsible for adhering to all grant requirements, including procurement and suspension and debarment compliance throughout 2025. We reaffirm our finding and will review the status of the finding during our next audit. Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2025 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 2024-002. Condition and Context The Town elected to receive the standard revenue loss allowance, allowing the Town to claim its total direct COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. Prior to entering into covered transactions with SLFRF award funds, recipients are required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under procurement and nonprocurement transactions (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person or adding a clause or condition to the covered transaction with that person. We sampled four vendors and related contracts to determine whether the Town verified the suspension and debarment status prior to payment. The Town had not verified the vendor's suspension and debarment status for one vendor prior to issuing payment. Federal expenditures to the vendor totaled $172,700. The lack of internal controls and noncompliance was isolated to the one vendor identified. 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 TOWN OF ZIONSVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; 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 the management of the Town. The Director of Finance and Records was not aware internal control over suspension and debarment was needed until after the prior (FY2024) audit engagement. 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 verified to be not suspended, debarred, or otherwise excluded. Any program funds the Town used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Additionally, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Other Matters Repeat Finding This is a repeat finding from the prior audit report. The prior audit finding number was 2024-002. INDIANA STATE BOARD OF ACCOUNTS 16 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 or services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor. Due to the U.S. Department of the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Covered transactions in the amount of $2,256,164 were made during the audit period to five vendors. Of the five vendors, four included a suspension and debarment clause and/or certification. For one vendor with expenditures that totaled $45,714, the County did not check the EPLS, nor was a certification collected from the vendor, and a clause did not exist in the agreement with the vendor. Although the County had a policy to include a clause in vendor contracts related to covered transactions, no documentation to verify the County's compliance with the suspension and debarment federal requirement was provided for audit. 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). . . ." 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; 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." INDIANA STATE BOARD OF ACCOUNTS 17 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The system of internal controls established by management of the County was not properly implemented to ensure that there was adequate documentation of the implementation of internal control policies and procedures. Effect Without the proper implementation of an effectively designed system of internal controls, the system is incapable of effectively preventing, or detecting and correcting, material noncompliance. As a result, no documentation was available for the status of one vendor to whom payment equal to or in excess of $25,000 was paid. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a system of internal controls to ensure that proper documentation is kept on file for each applicable vendor. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2025-002 - Procurement and Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services. Federal Program Names: Health Center Program and Grants for New and Expanded Services Under the Health Center Program. Assistance Listing Numbers: 93.224 and 93.527 Federal Award Identification Numbers and Years: Health Center Program Cluster: H80CS00626‐2023, H8KCS49691-2023, H8KCS49691-2024, H8ICS53459-2024 Criteria In accordance with 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition During our audit, we noted that BCHN did not perform a check at the System for Award Management Exclusions (sam.gov) to verify whether a vendor had been suspended or debarred before being hired. Cause As a result of personnel changes, the check was not timely performed. Effect or Potential Effect The condition could result in vendors who are suspended or debarred receiving federal funds. Questioned Costs None. Context One exception from a statistically valid sample of eight. Identification as a Repeat Finding Yes (see prior year finding number 2024-002) Recommendation We recommend Human Resources (HR) personnel/management perform a check at sam.gov prior to the hire of an vendor to ensure the vendor was not suspended or debarred and retain evidence of that verification, including the date it was performed. Views of Responsible Officials The vendor that was selected during the audit was hired in March of 2025. Since that time, BCHN has implemented a process by which all new employees and new vendors are added to the Exclusion Screening LLC database. We engaged Exclusion screening LLC because they check for exclusion and debarment on the OIG, SAM and state exclusion lists monthly, once entered in the system. This process ensures that all new vendors or employees are screened upon hire and are then automatically screened going forward. Bronx Community Health Network, Inc. and Affiliate Schedule of Findings and Questioned Costs Year Ended December 31, 2025 38

2025-001 Suspension and Debarment Federal Agency: U.S. Department of Labor Federal Program Title: Reintegration of Ex-Offenders Assistance Listing No. 17.270 Award Periods: July 1, 2023 – December 31, 2026 Type of Finding: • Material Weakness in Internal Control Over Compliance – Suspension and Debarment • Other Matter Questioned Costs: None Condition: During our testing of 5 suspension and debarment samples, CLA noted no documentation was maintained related to verifying vendors were not suspended or debarred for any of the 5 samples (100%) prior to disbursement. The statement of work outlines use of all of these vendors, but inclusion in the description in the statement of work of entities does not preclude the requirement to test for suspension and debarment issues. Though verification was done at the time of the audit, no support could be provided to show the control took place prior to use of the vendor. Criteria: Uniform Grant Guidance (200.214) states the non-Federal entity is subject to the debarment and suspension regulations as 2 CFR part 180, requiring no federal funds be awarded to parties that are suspended, debarred, or otherwise excluded from federal programs. Context: The Organization did not maintain adequate documentation related to verification that vendors were not suspended or debarred prior to use of such vendor for the 5 items sampled. The sampling methodology used is not, and is not intended to be statistically valid. Effect: Failure to properly approve contractors and maintain documentation may result in federal funds being charged to the grant for activities related to suspended or debarred vendors. Cause: The Organization did not have effective internal controls over compliance in place to ensure documentation of suspension and debarment procedures were followed prior to use of the vendor. Repeat Finding: The finding is a repeat of the prior year finding number 2024-001. Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and retain documentation evidencing the verification performed. Views of Responsible Officials: There is no disagreement with the audit finding.

Criteria or Specific Requirements: In accordance with 2 CFR Part 180 and 2 CFR 200.214, non-Federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred from participating in Federal programs. Before entering into a covered transaction, entities should verify that the party is not suspended or debarred by checking SAM.gov, collecting a certification from the party, or adding a clause or condition to the covered transaction. Effective internal controls should be designed, implemented and documented to ensure compliance with suspension and debarment requirements, including retaining evidence that verification was performed. Condition: The Organization did not maintain documented evidence that suspension and debarment verification procedures were performed for covered transactions. Per inquiry with the Executive Director, the Organization reviews SAM.gov before entering into covered transactions; however, the Organization does not retain screenshots or other evidence of these reviews. Management also informed HG that, for individuals located outside the United States who do not appear in SAM.gov, the Organization follows alternative procedures in which it contacts staff on the ground to obtain clearance, such as police clearance, before engaging these individuals. These alternative procedures were performed through phone calls and were not documented. Cause: Internal controls over suspension and debarment compliance were not designed to require documentation of verification procedures. Specifically, the Organization did not retain evidence of SAM.gov reviews, and the alternative procedures performed for individuals located outside the United States were conducted informally through phone calls without supporting documentation. Effect: Failure to independently verify and document the suspension and debarment status of vendors increases the risk that the Organization could enter into covered transactions with ineligible entities, resulting in noncompliance with Federal requirements. Questioned Costs: Questioned costs were not identified. Perspective Information: During testing of suspension and debarment compliance, eight vendors were selected for testing, seven located in Iraq and one located in Denmark. The Organization was unable to provide documentation demonstrating that suspension and debarment verification procedures had been performed for the vendors selected. As a result, HG independently verified the suspension and debarment status of all eight vendors through SAM.gov and confirmed that none of the vendors tested were suspended or debarred. No instances of noncompliance were identified. Repeat Finding: None. Recommendations: HG recommends that management document procedures requiring suspension and debarment verification for all covered transactions. Management should retain screenshots or other evidence of SAM.gov reviews performed before entering into covered transactions. For individuals located outside the United States, management should continue to perform SAM.gov searches and retain evidence of those searches, and should also obtain and retain documentation of alternative procedures performed, such as a police clearance certificate. Management should also incorporate supervisory review procedures to ensure verifications are completed and documented in accordance with Federal requirements.

FINDING 2025-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the prior audit report. The prior audit finding number was 2024-002. Condition and Context Recipients of the COVID-19 - State and Local Fiscal Recovery Funds are required to verify before entering into subawards and covered transactions that 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, such as a grant agreement, when the value is expected to equal or exceed $25,000. Verification may be performed by checking the Excluded Parties List System, obtaining a certification from the entity, or including an appropriate clause or condition in the transaction. The County did not have procedures in place to verify that entities were not suspended, debarred, or otherwise excluded from participation in federal assistance programs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. 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 BOONE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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." 31 CFR 19.300 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 the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Part 4 of the Treasury's Compliance and Reporting Guidance states in part: ". . . recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance . . ." Cause Management did not design an adequate system of internal controls. The County was unable to provide documentation demonstrating the verification that contractors and vendors were not suspended or debarred. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system could not effectively prevent, or detect and correct, material noncompliance. As a result, vendors receiving payments equal to or exceeding $25,000 were not verified to ensure they were not suspended, debarred, or otherwise excluded. Noncompliance with federal statutes, regulations, and terms and conditions of federal awards could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County strengthen its internal control system to ensure that all vendors receiving payments of $25,000 or more, in whole or in part with federal funds, are verified as not suspended or debarred from participating in federal programs before entering into any 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 Federal Transit Cluster – Assistance Listing 20.507 – Suspension and Debarment Questioned Costs: None identified. Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Documentation was not available to indicate the City verified vendors suspension and debarment before awarding and/or extending the contract during the fiscal year. The City’s internal controls did not ensure that the date the search was performed was maintained to ensure that the City performed the search prior to procurement. Context: See above condition. Cause: The City did not have a procedure in place to require documentation be maintained that the search for suspension and debarment associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect: Certain vendors could be used that are suspended or debarred by the federal government resulting in noncompliance. Recommendation: We recommend that the City review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: There is no disagreement with the audit finding.

Finding 2025-002 – I. Procurement and Suspension and Debarment Information on the Federal Program: Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Program Name: Congressional Directives Assistance Listing Numbers: 93.493 Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D 200.320 – Procurement methods – requires entities to maintain documented procurement procedures and appropriate supporting documentation for procurement methods, including noncompetitive procurements. Purchases below the simple acquisition threshold, but above the micro-purchase threshold, require price and rate quotations to be obtained from an adequate number of qualified sources. Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 - 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 Health System did not retain documentation demonstrating either (1) competitive bidding was performed or (2) the justification and circumstances supporting the use of a noncompetitive procurement method for equipment, installation and broadband services purchased under the grant. The procurement transactions reviewed exceeded the micro-purchase threshold; however, no supporting competitive procurement or sole-source documentation was available for audit inspection. The Health System has an established process to monitor vendor suspension and debarment requirements. Management’s process includes suspension and debarment evaluations on all new vendors prior to entering into any business relationship. The Health System utilized a third party to perform monthly suspension and debarment reviews; however, vendors associated with the program were not included in the listings provided to the third party for review. As a result, the Health System could not demonstrate that required suspension and debarment procedures had been performed for applicable vendors. Cause: Controls over the retention and maintenance of procurement documentation were not operating effectively to ensure that competitive procurement activities or sole-source justifications were documented and retained in accordance with Federal requirements. Controls over the identification and submission of vendors subject to suspension and debarment review were not operating effectively to ensure all applicable program vendors were included in the monthly review process performed by the third party. Effect or potential effect: Failure to maintain procurement documentation supporting competition or sole-source justification may result in noncompliance with Federal procurement requirements and limits the Health System's ability to demonstrate that contracts were awarded in accordance with Federal regulations. Failure to perform and document required suspension and debarment procedures increases the risk that the Health System could enter into a covered transaction with a suspended, debarred, or otherwise excluded party, resulting in noncompliance with Federal requirements. Questioned costs: Questioned costs totaled $2,299,513 and represent procurement transactions exceeding the micro-purchase threshold for which competitive procurement or sole-source documentation was not available for audit inspection. Although the costs are questioned due to the lack of required procurement documentation, the audit team noted the costs appear allowable. No questioned costs were noted for suspension and debarment. Audit procedures performed by the audit team determined that none of the vendors tested were suspended or debarred. Context: The population consisted of 20 procurement transactions. We selected a sample of 5 procurement transactions for testing and identified exceptions in all 5 items tested. For each transaction selected, the Health System was unable to provide documentation demonstrating that competitive bidding occurred or documentation supporting the circumstances that would allow for the use of a noncompetitive procurement method at the time the procurement occurred. The population consisted of 8 vendors associated with the Congressional Directives program. We selected a sample of 5 vendors for testing and identified exceptions for all 5 vendors. Specifically, several of the vendors selected for testing did not appear on a sample of 6 monthly vendor listings provided to the third party responsible for performing suspension and debarment reviews. As a result, the Health System could not demonstrate that the required suspension and debarment procedures had been performed for those vendors. Although these vendors were not subjected to the Health System's suspension and debarment review process, our independent verification procedures noted that none of the vendors tested were suspended or debarred. Identification as a repeat finding, if applicable: Not a repeat finding. Recommendation: The Health System should strengthen its internal controls over procurement and suspension and debarment compliance to ensure: (1) procurement files contain and retain documentation supporting competitive procurement procedures or noncompetitive procurement justifications, as applicable; and (2) all vendors subject to Federal suspension and debarment requirements are identified, included in the review process, and appropriately documented. Views of Responsible Officials: Management agrees with the findings. The Health System has established procurement policies and procedures; however, the purchases identified in the audit were not consistently processed through the established procurement review process, and the required supporting documentation was not retained. The purchases involved IT equipment, installation, and broadband services necessary for the project. Management believes the vendor selections were supportable as sole-source procurements based on technical compatibility, integration with existing IT infrastructure, continuity of implementation and support, and specialized vendor capabilities. Management determined that the associated costs were allowable. Corrective action will focus on reinforcing departmental compliance with the existing procurement policy, requiring procurement’s involvement before vendor engagement, and ensuring that competitive bidding documentation or an approved sole-source justification is retained for all federally funded purchases. Although the Health System has an established suspension and debarment screening process, certain vendors associated with the Federal program were not included in the screening population. Management will implement a documented reconciliation of federally funded vendors to the screening population, including supervisory review and resolution of any exceptions, to ensure that all applicable vendors are screened and evidence of the screening is retained. No questioned costs were identified, and subsequent to the transaction, management verified that none of the vendors tested were suspended or debarred at the time of the transactions.

Department of Energy, Federal Financial Assistance Listing 81.254, DE-GD0000886, 2025 Grid Infrastructure Deployment and Resilience 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 the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards to sections 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions to be included in contracts if criteria are applicable. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contract with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: Testing of procurement activities and related controls identified the following exceptions: • The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. • One contract tested did not contain all applicable Uniform Guidance contract provisions. • In one instance involving a contract exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Cause: The Cooperative had not established procedures to periodically evaluate its procurement policy and procurement documentation for compliance with Uniform Guidance requirements, including required contract provisions, documentation of procurement decisions, and suspension and debarment verification procedures. Effect: Failure to maintain effective controls over procurement activities increases the risk of noncompliance with federal procurement requirements. As a result, the Cooperative may enter into contracts that do not contain required federal provisions, fail to adequately document procurement decisions, or engage in covered transactions with vendors that are suspended or debarred from participation in federally funded programs. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: No Recommendation: We recommend that the Cooperative update its procurement policy to incorporate all applicable Uniform Guidance requirements. Management should also establish and implement procedures to: • Verify and document suspension and debarment reviews for all applicable covered transactions. • Review contracts prior to execution to ensure all required Uniform Guidance contract provisions are included. • Maintain documentation evidencing compliance with federal procurement requirements. Views of Responsible Officials: Management agrees with the finding.

2025-002 Procurement, Suspension and Debarment - Compliance and Internal Control Finding – Material Weakness Federal Agency - U.S. Department of Treasury Federal Award Number - 21.027: Coronavirus State and Local Fiscal Recovery Funds Pass-Through Entity - Kansas Department for Aging and Disability Services Criteria Or Specific Requirement: In accordance with 2 CFR §200.318 through §200.327, non-federal entities are required to establish and maintain documented written procurement policies and procedures for purchases funded with federal awards. Additionally, pursuant to 2 CFR §180 and 2 CFR §200.214, non-federal entities are prohibited from contracting with or making covered transactions with parties that are suspended or debarred from participating in federal programs. The Uniform Guidance requires entities to verify that vendors are not suspended or debarred through SAM.gov or through other allowable methods and to maintain documentation supporting the verification. Condition: During testing of procurement transactions and vendor payments charged to federal programs, it was noted that the Organization did not perform or document suspension and debarment verification procedures prior to entering into covered transactions with vendors paid from federal awards. Additionally, the Organization was unable to provide evidence that competitive procurement methods, cost or price analyses, vendor selection procedures, or suspension and debarment reviews were consistently performed for federally funded purchases. Cause: Management has not established or implemented formal procurement policies and procedures designed to comply with Uniform Guidance procurement standards. In addition, management has not developed a process to perform and document suspension and debarment checks before executing contracts or making covered transactions funded by federal awards. As a result, internal controls over procurement and suspension and debarment compliance have not been designed, implemented, or monitored effectively. Effect: The lack of documented procurement procedures and suspension and debarment verification controls increases the risk that federal funds may be expended in a manner that does not comply with Uniform Guidance requirements. The Organization may inadvertently procure goods or services from suspended or debarred vendors, fail to obtain full and open competition, or otherwise incur expenditures that could be determined to be unallowable by federal awarding agencies. This deficiency could result in questioned costs, repayment of federal funds, increased monitoring by grantors, and damage to the Organization's reputation as a federal award recipient. For The Year Ended December 31, 2025 Questioned Costs: None. Context: A sample of procurement transactions and vendor disbursements charged to federal awards was tested. For all applicable transactions selected for testing, the Organization was unable to provide evidence of documented procurement procedures or suspension and debarment verification. No written procurement policy existed, and no evidence of SAM.gov searches or other allowable suspension and debarment verification methods was maintained. Identification As A Repeat Finding: No. Recommendation: We recommend that management develop, formally adopt, and implement written procurement policies and procedures that comply with the requirements of Uniform Guidance. The policies should address procurement methods, documentation standards, competition requirements, conflict-of-interest provisions, cost and price analysis requirements, and vendor selection procedures. In addition, management should establish controls requiring documented suspension and debarment verification through SAM.gov or other allowable methods before entering into covered transactions with vendors funded by federal awards. Evidence of all compliance procedures should be retained and reviewed by supervisory personnel. Views Of Responsible Officials: Management agrees with the findings and acknowledges that formal procurement and suspension and debarment procedures have not been established. Management intends to develop and implement written policies and procedures, provide staff training, and establish a vendor verification process designed to ensure compliance with Uniform Guidance procurement and suspension and debarment requirements.

Department of Veteran Affairs FFAL #64.033, 20-SD-136-25, 10/1/2024 – 12/31/2025 FFAL #64.033, 20-SD-136-26, 10/1/2025 – 9/30/2026 VA Supportive Services for Veteran Families Program Procurement, Suspension & Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform with procurement standards in sections 200.317 through 200.327. Additionally, 2 CFR 200.214 requires recipients to restrict making contracts with certain parties that are debarred, suspended, or excluded from participating in Federal awards. Condition: Testing of the federal program identified the following: a. The Organization’s formally documented procurement policy is missing one required element as it relates to domestic preferences (2 CFR 200.322). b. Two lease agreements were entered into where the Organization did not follow the procurement process as detailed in the procurement policy. The lease agreements with the vendors were also missing a required contract provision in accordance with Uniform Guidance and there was no review performed by the Organization to ensure the vendors were not suspended or debarred as the lease agreements with the vendors were over $25,000. Cause: Individuals with key roles over compliance reporting were not involved in the Organization’s compliance reporting activities for the full year. Contract provisions were not evaluated compared to Uniform Guidance contract requirements. Lease agreements entered into were not evaluated in accordance with Uniform Guidance as it relates to suspension and debarment. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Organization would be noncompliant with the compliance requirements outlined above. Additionally, the Organization may enter into a covered transaction with a vendor that is suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 2 out of 4 vendors were selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the Organization update their procurement policy to ensure it includes the required elements as it relates to domestic preference. In addition, we suggest that management implement procedures and control processes related to the review of contracts to ensure the procurement methods are being followed, documentation is being retained, and that the contracts include the required Uniform Guidance provisions. Also, management should ensure vendors are not suspended or debarred from doing business with the federal government. Views of Responsible Officials: Management agrees with the finding.

2025-004 Procurement Policy Criteria: Under 2 CFR §200.318 through 200.327, General Procurement Standards, a non-federal entity must use and document procurement procedures for the acquisition of property or services required under a federal award or subaward. Additionally, the non-federal entity must include policies and procedures related to competition, informal and formal procurement methods, and noncompetitive procurement known as sole source. 2 CFR §200.214, Suspension and Debarment, requires entities to verify that vendors are not suspended or debarred from participating in federal funds. Condition: There is no evidence of a documented formal procurement policy with regards to federal grant awards and expenditures; no documented support that a competitive price analysis for vendors and organizations funded with federal grant funds were performed; and no evidence that suspension and debarment verifications were performed for certain vendors and organizations, as required by the general procurement standards of the Uniform Guidance. Context: We tested all procurement transactions totaling $863,741. All transactions tested lacked documentation to demonstrate compliance with the applicable procurement requirements of the Uniform Guidance. Cause: Management had not established and formally adopted procurement policies and procedures consistent with Uniform Guidance requirements during the audit year. Effect: Without documented procurement policies, there is an increased risk that procurements may not be conducted in accordance with Federal requirements, resulting in potential noncompliance with the Uniform Guidance. Charges relating to vendor services and sub-awards that were charged to the federal award may not be in accordance with the specific compliance requirements of the Uniform Guidance. Recommendation: We recommend that management develop, formally adopt, and implement written procurement policies and procedures that comply with the procurement standards in 2 CFR §200.317 through 200.327 and provide training to personnel responsible for purchasing. We also recommend the Organization to adopt policies that incorporate the requirements of 2 CFR §200.214 regarding suspension and debarment regulations. We also recommend that a review of all existing vendor contract filed be performed to ensure that the documentation, as required by the Uniform Guidance, is maintained in the files.Views of Responsible Officials and Planned Corrective Actions: The Organization is in the process of developing a corrective action plan and provide personnel training.

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

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

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

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

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

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

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