Findings Citing § 200.214

2024-002—SUSPENSION AND DEBARMENT Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instance of Noncompliance related to Federal Awards Funding Agency U.S. Department of Agriculture (“USDA”) Programs Beginning Farmer and Rancher Development Program; Award: BFRDP-2023-49400-40894 (AL 10.311); Period: 09/15/2023-09/14/2026 Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937); Period: 11/02/2023 -11/01/2028 Questioned Costs None identified Statement of Condition Quivira does not have a process to or adequately document its review process to confirm vendor suspension and debarment status prior to entering into federally funded transactions. Also, the policies and procedures do not have clear procedure of vendor checking for debarment and suspension. Quivira has checked three entities during the Audit with no negative results. Criteria Non-Federal entities must ensure covered transactions are not with excluded parties (2 CFR Part 180, e.g., §180.300) as required by 2 CFR §200.214. Verification may be via SAM.gov, certification, or contract clause, with documentation retained. Cause Procurement policy lacks clear Suspension and Debarment steps and required documentation; staff is not trained on timing/evidence. Effect or Potential Effect Not adequately verifying suspension and debarment could result in Quivira engaging federally funded vendors who are prohibited from participating in federal programs, potentially causing disallowed costs, repayment obligations, or the loss of future federal funding. Recommendation We recommend Quivira: Update procurement policies promptly to fully comply with all applicable federal procurement guidelines. Clearly define the federal small purchase threshold and include procedures for obtaining price quotations. Establish and implement documented processes for verifying and recording suspension and debarment checks before engaging in covered transactions. Provide ongoing training for procurement staff to ensure proper understanding and consistent application of federal procurement standards, specifically regarding small purchase procedures and suspension/debarment checks. Views of Responsible Officials and Planned Corrective Action Management agrees with the recommendation. To address this significant deficiency, Quivira Coalition will: Action Step Detail Date Responsible Party Update its Procurement Policy to fully comply with all applicable federal procurement guidelines including clearly defining the federal small purchase threshold, updating procedures for obtaining price quotation, adding procedures for checking suspension & debarment and documenting results before engaging in transactions. 10/31/25 Drafting: Operations Director & Executive Director Review Changes: Board of Directors financial committee Approval: Board of Directors Implement the procedure to check suspension or debarment with potential subrecipients, contractors and other persons related to covered transactions before entering into a covered transaction by the methods given in 2 CFR § 180.300. The documentation showing the check or certification that a person is not suspended or debarred will be saved in the grants and financial files. Once it has been confirmed the person is not suspended or debarred, then the transaction may be entered into. 10/31/25 Operations Director & Executive Director Conduct an annual training for all staff currently involved with government awards including programmatic staff plus financial and grant management staff on the updated procurement policies with special focus on small purchase procedures and suspension/debarment checks. It will also build into its grant lifecycle regular review of these procedures during application/negotiation, implementation and reporting phases. 11/30/25 Operations Director and Grants manager Incorporate a semi-annual review of procurement files to ensure compliance with the new procedures. Findings from these reviews will be reported to management. 1/31/26 Operations Director

2024-005 - Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment) Programs. Environmental and Scientific Partnerships and Programs; U.S. Department of State; ALN Number 19.017; Award Number SAQMIP23CA0021 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 is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During Procurement, Suspension and Debarment testing, the Organization could not provide evidence that they determined whether vendors are suspended or debarred. Cause. The Organization did not have a procedure in place to require documentation be maintained that the search for suspension and department 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 considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. None Recommendation. We recommend that the Organization adhere to the policy over suspension and debarment review to ensure they are contracting with vendors that are allowable. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Information on the federal program – 21.027 – Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Dallas County; Program years 2023-2024, 2024-2025 16.575 – Crime Victim Assistance; U.S. Department of Justice; Texas Office of the Governor – Criminal Justice Division; Program years 2023-2024, 2024-2025 Type of Finding – Significant deficiency in internal control over compliance and other instance of noncompliance Criteria or specific requirement – The Uniform Guidance requires auditees to maintain internal controls to prevent or identify and correct noncompliance with direct and material compliance requirements in a timely fashion, specifically in regard to Procurement (2 CFR 200.320) and Suspension and Debarment (2 CFR 200.214). Condition – The Family Place was unable to provide evidence supporting procurement for a particular vendor, as well as evidence supporting verification of a lessor not having been suspended or debarred occurred during the year. Cause – The auditee's controls did not properly identify necessary procurement and suspension and debarment processes to undertake as required by policy and Uniform Guidance. Effect or potential effect – Procurement did not occur for one vendor relationship selected. Evidence of verification of vendor status of one lessor selected was not available. Questioned costs – $10,837 (ALN 21.027) Context – Procurement: Of three covered procurement transactions identified for ALN 21.027, 100% were selected for testing, the total of which was $58,517. One transaction did not have documented procurement procedures having taken place. The total of the transaction resulting in questioned costs was $10,837. Suspension and Debarment: Of two lessors with expenditures greater than $25,000 for ALN 16.575, one was selected for testing of suspension and debarment. While the lessor was not listed as having been suspended or debarred on SAM.gov, evidence of review occurring was not available. Identification as a repeat finding, if applicable – Not applicable Recommendation – We recommend management review all contracts with vendors and review the procurement policy to ensure compliance with the procurement and suspension and debarment standards within their policy and the Uniform Guidance. Views of responsible officials and planned corrective actions – See accompanying corrective action plan.

2024-001: Significant Deficiency Over Compliance with Procurement and Suspension and Debarment Federal Program: Highway Planning and Construction and Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number(s): 20.205 and 21.027 Federal Agency: U.S. Department of Transportation and U.S. Department of Treasury Pass-through Entity: Colorado Department of Transportation (20.205 only) Criteria: 2 CFR 200.319 states that all procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with Federal procurement standards. 2 CFR 200.214 states in part that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations. In addition, 2 CFR 200.303 in part states that a recipient of a Federal award must establish, document, and maintain effective internal control over the Federal award. Condition: We have selected and tested vendors for suspension and debarment with expenditures in excess of $25,000 for the Bridge CR-397 and EMS projects for compliance with suspension and debarment. We identified that two vendors were not properly verified for suspension and debarment prior to the contract execution date. Cause: Internal controls over suspension and debarment were properly designed but not operating effectively to verify that all vendors are in compliance with suspension and debarment. Effect: Our testing identified that the County’s internal controls over compliance with suspension and debarment are not operating effectively, which may cause the County to be out of compliance with Federal and grant requirements. Repeat Finding: No. Recommendation: We recommend that the County re-evaluate the design of internal controls over suspension and debarment to be in compliance with the Federal requirements and the County’s procurement policy/procedures.

U.S. Department of Health and Human Services, passed through Kansas Department of Aging and Disability Services Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD ALN 93.053 - Nutrition Services Incentive Program - 2301KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency 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. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. 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 the subrecipient that received federal funds. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Effect: Federal funds could be paid to entities that are suspended or debarred. Questioned Costs: None noted. Context: Only one subrecipient received pass-through funding from the Unified Government. The single subrecipient under ALN 93.044, 93.045 and 93.053, receiving approximately $428,000, was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2023-006, 2022-007, 2021-005, 2020-002 Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: We agree with the finding. See management corrective action plan.

Finding No: 2024.002 Type: Significant Deficiency - Internal Control: Procurement Condition: We were not able to substantiate evidence of confirming suspension and debarment for vendors. Criteria: Under 2 CFR 200.214, non-federal entities must verify that subrecipients and contractors are not suspended, debarred, or otherwise excluded from participation in federal programs before entering into covered transactions. Checks should be performed using the System for Award Management (SAM). Internal control over compliance requirement related to suspension and debarment was not evidenced. Amount: not applicable Cause: The nonprofit does not have documented procedures to verify the suspension and debarment status of entities prior to awarding contracts or subawards. No evidence was available to confirm that such checks were performed for current awards. Effect or Potential Effect: Absence of adequate suspension and debarment screening increases the risk of federal funds being awarded to ineligible parties, potentially resulting in repayment of those funds, audit findings, and possible exclusion from future grant programs. Repeat Audit Finding: no Recommendations: Implement and document procedures requiring SAM exclusion checks prior to issuing federal subawards or contracts and maintain records of these checks. Provide staff training on regulatory requirements regarding suspension and debarment, and regularly review compliance to ensure ongoing adherence.

SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Spokane Conservation District January 1, 2024 through December 31, 2024 2024-001 The District did not have adequate internal controls and did not comply with federal reporting, 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: N/A Background During fiscal year 2024, the District spent $690,786 in federal funds from the Inflation Reduction Act Urban & Community Forestry Program. Of this amount, it passed $149,765 through to two subrecipients. 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. 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. Reporting The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients that make first-tier subawards of $30,000 or more to report them in the FFATA Subaward Reporting System (FSRS). The District must report subawards by the end of the month following the month in which it made the subawards. Suspension and debarment Federal requirements prohibit recipients from contracting with, purchasing from and making subawards to 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, and for all subawards regardless of award amount, paid all or in part with federal funds, it must verify the contractors and subrecipients 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 and subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient 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 before making subawards, and must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Reporting The District’s internal controls were ineffective for ensuring it submitted FFATA reports for its subawards on time as federal regulations require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Suspension and debarment Although the District has a process to verify the suspension and debarment status for contractors and subrecipients, our audit found the District did not follow this process. The District did not verify one contractor out of three contractors and subrecipients we tested was not suspended or debarred before purchasing from them. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Reporting District staff were unaware of the federal FFATA reporting requirements for the program until the time of audit. Suspension and debarment District staff said they were aware of the requirements, but could not locate documentation to show they verified the contractor’s suspension and debarment status. Effect of Condition Reporting Failing to submit the required reports diminishes the federal government's ability to ensure accountability and transparency of federal spending. The table below summarizes the discrepancies we identified. Because the District did not submit the reports until our audit in September 2025, we did not audit the accuracy and completeness of them. 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 $335,385 using 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 Reporting We recommend the District strengthen its internal controls to ensure it prepares and submits complete and accurate FFATA reports for all applicable subawards by the due date, as federal regulations require. 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 retain documentation demonstrating compliance with this requirement. District’s Response We concur that the FFATA Subaward Reporting System (FSRS) reporting was not completed within the required timeframe. Upon identification of the reporting gap, the required subaward reporting was completed. We also concur that documentation was not retained for the suspension/debarment check for one contractor. The contractor was verified as not suspended or debarred; however, the documentation was not included in the project file. To strengthen internal controls and prevent future occurrences, the District is implementing the following corrective actions: • Policy & Procedure Updates: Updating federal grant management and procurement procedures to formalize FFATA reporting timelines, suspension/debarment documentation requirements, and staff responsibilities. • Centralized Tracking: Establishing a centralized tracking process for all applicable subawards, including FSRS reporting deadlines. • Documentation Standards: Requiring and documenting suspension/debarment checks at the time of procurement or subaward execution, consistent with 2 CFR 200.214 and related requirements. • Training: Incorporating suspension and debarment requirements into annual contract and procurement training. • Periodic Internal Review: Implementing internal reviews of a sample of federally funded contract files to verify that reporting and eligibility documentation are timely and complete. The framework will be in place by December 31, 2025. 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 the status of the District’s corrective action during our 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 170, Reporting Subaward and Executive Compensation Information, establishes the Federal Funding Accountability and Transparency Act (FFATA) requirements of reporting the subaward information through the FFATA Subaward Reporting System (FSRS). 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.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027, Passed through the Pennsylvania Department of Agriculture, Grant Period - Year ended December 31, 2024. Criteria: Title 2 CFR Section 200.214 of the Uniform Guidance subjects nonfederal entities to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The District did not verify the parties were not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal programs prior to awarding contracts. Cause: The District Manager was not aware of the District’s responsibility to verify that parties were not suspended or debarred. Effect: Contracts under the federal program may improperly be awarded to excluded or ineligible parties. Questioned Costs: None. Perspective Information: Not applicable. Identification of Repeat Findings: Not applicable. Recommendation: The District should apply the guidance in section 200.214 of the Uniform Guidance in determining whether parties are excluded or ineligible for participation in Federal programs. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See the County’s corrective action plan.

Criteria: 2 CFR 200.319 states that all procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with Federal procurement standards. 2 CFR 200.214 states in part that recipients and subrecipients are subject to the suspension and debarment regulations. In addition, 2 CFR 200.303 in part states that a recipient of a Federal award must establish, document, and maintain effective internal control over the Federal award. Condition: We have selected and tested one vendor for suspension and debarment with expenditures in excess of $25,000 for the construction of a new shelter and office space for compliance with suspension and debarment. We identified the one vendor were not properly verified for suspension and debarment prior to the contract execution date. It appears that the vendor was not suspended or debarred by the federal government. Cause: Internal controls over suspension and debarment were not properly designed to verify that all vendors are in compliance with suspension and debarment. Effect: Our testing identified that the Organization’s internal controls over compliance with suspension and debarment are not in place to comply with the suspension and debarment requirements. Based on our testing, the vendor was in compliance with suspension and debarment. Repeat Finding: No. Recommendation: We recommend that the Organization re-evaluate the design of internal controls over compliance with suspension and debarment compliance requirements based on 2 CFR 200.214 and establish policies and procedures to comply with these requirements as they relate to requirements related to federal grants. Corrective Action Plan: Reported on page 20.

2024-5 Suspension and Debarment Verification Criteria: In accordance with 2 CFR §200.214 and the specific compliance requirement for Suspension and Debarment, non-Federal entities are prohibited from contracting with or making covered transactions with parties that are suspended, debarred, or otherwise excluded from participation in Federal programs. To comply, entities must verify the status of vendors and contractors prior to entering into covered transactions by performing one of the following: 1. Checking the System for Award Management (SAM.gov) exclusion listings, 2. Collecting a certification from the vendor, or 3. Adding a clause or condition in the contract confirming that the vendor is not suspended or debarred. Adequate documentation of the verification process must be maintained. Condition: During our audit, we noted that the Borough does not verify whether contractors or vendors receiving Federal funds are suspended or debarred from doing business with the Federal government. The Borough also does not maintain documentation demonstrating that such checks were performed. Cause: The Borough was not aware of the specific requirement to verify and document vendor suspension and debarment status for transactions funded with Federal awards. Effect: Failure to verify suspension and debarment status increases the risk that the Borough could enter into contracts or make payments to parties that are ineligible to participate in Federal programs. This exposes the Borough to potential noncompliance with Federal regulations and could result in disallowed costs or repayment of Federal funds.Recommendation: We recommend that the Borough establish and implement procedures to verify and document that all vendors and contractors receiving Federal funds are not suspended or debarred prior to entering into covered transactions. Acceptable procedures include checking vendor status on the SAM.gov website and printing or saving verification documentation, or obtaining vendor certifications confirming compliance. This review should be documented and retained for audit purposes.

Assistance Listing, Federal Agency, and Program Name - 20.941, U.S. Department of Transportation, Strengthening Mobility and Revolutionizing Transportation (SMART) Grants Program Federal Award Identification Number and Year - SMARTFY22N1P1G34-A01 Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The Road Commission could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Road Commission used the grant to procure services from one contractor, that was paid $1,894,112 with grant funds, and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Plante Moran reviewed the SAM.gov website noting the vendor was not listed as suspended or disbarred. Cause and Effect - The Road Commission did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Recommendation - We recommend the Road Commission implement controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Road Commission will establish formal policies around the internal review of contractors to ensure they are not suspended or debarred. In addition, the policy will ensure formal documentation of this review is maintained in the associated project.

Noncompliance with Procurement, Suspension, & Debarment Standard (Significant Deficiency) Federal Award Program: 21.027 COVID-19: Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.214 prohibits non-federal entities from contracting with parties that are suspended or debarred under covered transactions. Condition and Context: Audit procedures revealed that there was not a policy or process in place to formally document the review of the contracted entity for suspension and debarment prior to entering into the agreement. Cause: The Organization does not have a formal process to document suspension and debarment. Management was unaware of the requirement, though it was clear the management thoughtfully considered the contractor’s reputation and determined that the contractor was suited for the agreement. Effect: The Organization did not perform its review of suspension and debarment for this agreement, though the contractor was found to not be on prohibited lists at annual review. Questioned Costs: None Recommendation: Management should strengthen their processes, controls, and review over suspension and debarment processes, and develop a written policy on such items to ensure compliance with Uniform Administrative Requirements. Views of Responsible Officials and Planned Corrective Actions: As stated by the auditor, SCEC is selective about who to enter contracts with and has long-standing relationships with the organizations we were working with on these efforts, who also had other Federal contracts in process that we were aware of. We have instituted a finance procedure to check all contractors and sub-contractors on the Sam.gov’s verification of debarment and suspension tool before the first payment under the contract is issued and a policy that all SCEC contracts or subawards over $25,000 that utilize federal or state funds must include a suspension and debarment certification.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 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. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 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. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.

2024-001 U.S. Environmental Protection Agency/ U.S. Department of Treasury Federal Financial Assistance Listing 66.458 / 21.027 Capitalization Grants for Clean Water State Revolving Funds/ COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement Suspension and Debarment Material Weakness in Internal Control Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing over procurement, based upon discussions with management, the City had performed suspension and debarment check prior to entering into the transaction; however, the documentation was not retained, and we were unable to verify this during our testing. Cause: Documentation was not retained to prove the City verified the vendor was not suspended or debarred prior to entering into the transaction. Effect: We were not able to verify suspension and debarment was verified by the City prior to entering into the transaction. Questioned Costs: None reported. Context/Sampling: Nonstatistical sample was used. Repeat Finding from the Prior Year: No Recommendation: As part of the procurement process, we recommend the City retain documentation verifying suspension and debarment was verified prior to entering into transactions required to follow the procurement rules under 2 CFR 200, Section 200.214 Suspension and Debarment. Viewed of Responsible Officials: Management agrees with the finding.

2024-001 U.S. Environmental Protection Agency/ U.S. Department of Treasury Federal Financial Assistance Listing 66.458 / 21.027 Capitalization Grants for Clean Water State Revolving Funds/ COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement Suspension and Debarment Material Weakness in Internal Control Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing over procurement, based upon discussions with management, the City had performed suspension and debarment check prior to entering into the transaction; however, the documentation was not retained, and we were unable to verify this during our testing. Cause: Documentation was not retained to prove the City verified the vendor was not suspended or debarred prior to entering into the transaction. Effect: We were not able to verify suspension and debarment was verified by the City prior to entering into the transaction. Questioned Costs: None reported. Context/Sampling: Nonstatistical sample was used. Repeat Finding from the Prior Year: No Recommendation: As part of the procurement process, we recommend the City retain documentation verifying suspension and debarment was verified prior to entering into transactions required to follow the procurement rules under 2 CFR 200, Section 200.214 Suspension and Debarment. Viewed of Responsible Officials: Management agrees with the finding.

2024-001: PROCUREMENT (repeat comment) Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.969 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.

Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses. Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards. Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

2024-001 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information Funding Agency: U.S. Department of the Treasury Federal ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price." Condition The Chamber has a procurement policy in place; however, the Chamber neglected to verify if vendors had been suspended or debarred, in accordance with stated regulations. The Chamber also did not maintain sufficient records to document the rationale for the procurement method used for a transaction exceeding the small purchase threshold. Questioned Costs $25,000 Context A sample of 3 vendors was made from a population of 3 vendors whose expenses exceeded the covered transaction threshold that were charged to the major program. Of the 3 sampled vendors, the Chamber neglected to check the suspension or debarment status of 1 vendor prior to entering a covered transaction of $25,000. A sample of 3 vendors was made from a population of 3 vendors whose total transactions exceeded the small purchase threshold. Of the 3 sampled vendors, the Chamber did not maintain sufficient records to document the rationale of using a noncompetitive procurement method for a small purchase transaction. Cause The Chamber claimed that they had been conducting business transactions with this vendor prior to having a procurement policy in place and did not implement the procurement policy on already developed business relationships. The Chamber also did not consider documenting its rationale for continuing to use the vendor for services that exceeded the small purchase threshold that were charged to the major program. Effect Purchases may have occurred that do not follow the policy, and contracts with vendors that had been suspended or debarred could have been awarded and not detected. The Chamber also did not conduct procurement transaction "in a manner that provides full and open competition," as defined in 2 CFR 200.319(a). Repeat Finding Yes - reference 2023-001. Auditor's Recommendations Tacoma-Pierce County Chamber of Commerce should include a provision in all contracts transacted in conjunction with using funds originating from a federal award grant, with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify that vendors are not suspended or debarred. Chamber staff should also perform an independent status check of vendors in sam.gov prior to entering into an agreement and retain the search results. The Chamber should also evaluate its current method of procurement and educate staff that if using funds from a federal award to enter into a transaction exceeding the small purchase threshold, that full and open competition must be facilitated, despite any prior relationships with vendors.

Reportable Finding Considered a Significant Deficiency – Lack of Supporting Documentation for Search for Suspension and Debarment in Procurement Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhood Assistance listing #: 84.215K Program year: 2024 Federal Awarding Agency: Department of Education Compliance requirement: Procurement Criteria: According to 2 CFR §200.214, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. The primary method for ensuring compliance with this requirement is to perform a vendor search on SAM.gov. Other methods include having vendors self-certify or including a clause in the vendor contract. Condition: During our testing of procurement, it was noted that the Organization lacked support documenting a search for suspension or debarment of its vendors or use of the other methods for ensuring compliance. Cause: Policies and internal controls over procurement were not fully functioning during the year, due in part to turnover in the positions that were in charge of procurement. Effect: The risk of engaging a vendor who is suspended or barred from receiving federal funding or participating in federal award activities is increased. Questioned costs: There are no questioned costs related to this finding. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their policies and procedures surrounding procurement to require that one of the methods described above is utilized to ensure that no federal funding is passed to individuals or corporations that are barred from receiving it. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.

2024-001: PROCUREMENT, SUSPENSION, AND DEBARMENT Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.788 Opioid STR Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, either formal procurement methods, or documentation of noncompetitive procurement, are required. Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to 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 document the noncompetitive procurement process pursuant to 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Cause/Effect: Management oversight. Questioned Cost: None Context: Due to an immediate, unexpected need for specialized services, the CMHSP entered into a contract with a vendor established with the PIHP, but did not document the noncompetitive procurement process pursuant to 2 CFR 200.320. Also, upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that formal procurement methods are documented and verification of suspension, debarment, or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.

Criteria - According to the Coronavirus State and Local Recovery Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition - During our testing, it was noted that 1 of 5 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause - The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect - In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation - We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.

Criteria - According to the Coronavirus State and Local Recovery Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition - During our testing, it was noted that 1 of 5 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause - The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect - In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation - We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.

FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.