Findings Citing § 200.302

2024-002 Internal Controls over Grant Management (Significant Deficiency and Noncompliance) Criteria: 2 CFR 200.302 establishes the requirements of a financial management system adequate to ensure compliance with federal regulations. This system must include written procedures to implement requirements for payment methods and determine the allowability of costs in accordance with subpart E. Statement of Condition: The City has written fiscal policies but they do not meet the financial management system requirements established in the regulations. Cause: The City has processes and procedures in place to administer grant funds but written policies do not contain compliance requirements. Effect: The City is not in compliance with financial management system requirements. Recommendation: The City should develop a grants manual or additional written policies to incorporate all the requirements of 2 CFR 200 and ensure compliance. Views of Management and Planned Corrective Action: See Corrective Action Plan included at the end

Federal Programs: U.S. Department of Health and Human Services, Consolidated Health Centers Cluster: Community Health Centers (Assistance Listing #93.224 & 93.527) Finding Type: Significant Deficiency in Internal Control over Compliance Criteria: The 2 CFR Section 200.302 requires that nonfederal entities receiving federal awards present accurate, current, and complete disclosure of the financial results of each federal award or program. The entity is required to maintain records, supported by source documentation, that identify adequately the source of funds for federally funded programs and report federal expenditures via the Federal Financial Reports at intervals specified within the applicable grant awards. Condition and Context: For the annual submission of the H80CS24107 grant, the center submitted the required federal financial report 91 days after the date the report was due. Cause: During the year, the Center experienced turnover within the finance department and which cause a lapse in duties pertaining to the submission of this report. Effect: As a result the report was not filed timely, there was no noted financial impact of the late submission. Questioned Costs: None Recommendation: The Center should implement a more robust process and related internal controls surrounding the reporting of grant expenditures. Views of Responsible Officials: Management agrees with the finding. Planned Implementation of Corrective Action: Additional preventive internal control procedures will be implemented, designating a secondary individual responsible for submission should the primary individual leave or be terminated. These procedures and internal controls have been implemented as of the date of this report. Person Responsible for Corrective Action: Chief Executive Officer

2024-032 - Delayed Final Reimbursement Due to Unresolved Agency Requests Federal Programs 23.002 - Appalachian Area Development 14.228 - Community Development Block Grants/State's Program Award Numbers ARC-20698 ARC-20699 CDBG Subgrant: 1137-21-111-PF-01 Federal Agency U.S. Department of Housing and Urban Development (HUD) Appalachian Regional Commission (ARC) Compliance Requirement Reporting and Closeout- 2 CFR §§ 200.302, 200.303, and 200.344 Type of Finding: Internal Control over Compliance - Significant Deficiency Compliance - Noncompliance Questioned Costs: None Criteria: In accordance with 2 CFR §200.302 and §200.303, non-federal entities must maintain effective internal control over federal awards and ensure timely closeout. Additionally, 2 CFR §200.344 requires that closeout be completed within one year of the end of the period of performance. Condition: Final reimbursement requests for the above federal programs were submitted over a year ago. Although the granting agencies have initiated follow-up correspondence requesting additional documentation or clarification, the final payments remain outstanding as of the audit date. No resolution has been reached, and the grants remain open. Cause: The City lacks a formalized process for tracking unresolved reimbursement requests and responding to agency inquiries in a timely and coordinated manner. This has contributed to delays in resolving outstanding issues and receiving final payments. Effect: The City has not received final reimbursement for completed federal programs, resulting in delayed revenue recognition and potential strain on local resources. The extended delay also risks noncompliance with federal closeout requirements and may affect future funding eligibility. Recommendation: Implement a grant closeout protocol that includes: A centralized tracking system for final reimbursement submissions and agency correspondence Defined timelines for follow-up and escalation Clear assignment of responsibility for resolving outstanding issues Views of Responsible Officials: Management concurs with the finding. The City acknowledges that final reimbursement requests for the referenced federal programs were submitted in a timely manner; however, final payments have not been received due to ongoing correspondence and requests for additional information from the granting agencies. While staff have responded to these inquiries, the absence of a formalized tracking and escalation process has contributed to delays in resolution.

Criteria: As noted in finding 2024-002, an effective internal control system should be designed and clearly documented. A key part of the documentation is the use of documented policies and procedures. The policies and procedures should cover general accounting and operational processes as well as compliance with State and Federal regulations as applicable. Federal regulations impacting the Organization include Title 2 CFR 200.318, Title 2 CFR 200.302(b), Title 2 CFR 200.313(d) and Title 2 CFR 200.403(d) (Factors Affecting Allowability of Costs). Condition: As noted in finding 2024-002, Every Woman's Place, Inc. did not have effective policies in place over payroll cost allocations, non-payroll cost allocations, procurement, gift cards, equipment inventory and other indirect program cost allocations. Cause: The Organization did not develop, design or implement adequate internal control policies over key required processes. Effect: As part of the audit, it was determined that indirect costs listed in the Financial Status Reports (FSR) for various programs passed through from the State of Michigan Department of Health and Human Services may have been erroneously calculated leading to questioned costs. The lack of internal controls could also lead to misstatements of financial activity and related program reports. The lack of such policies and procedures increases the risk of error, omission, fraud and abuse in financial statements and related activities. Context: A program audit was performed by the State of Michigan’s Department of Health and Human Services for the fiscal year ending September 30, 2023 (dated November 21, 2025). Based on additional items noted by the State of Michigan, it was determined that indirect costs appear to have been incorrectly calculated. These items were directly related to the lack of clarity and/or policy of the direct / indirect cost methodology being utilized Questioned Costs: Indirect costs presented on FSRs for the fiscal year ended September 30, 2024, that represent questioned costs is $83,141 Recommendation: The Organization should review accounting policies to ensure that the policies are up-to-date and, if applicable, in compliance with the State and Federal Regulations. The Organization should also adopt a proper allocation methodology for direct and indirect costs and require board-approval and annual certification. View of Responsible Officials and Planned Corrective Actions:

Finding No.: 2024-012 Federal Agency: U.S. Department of Agriculture AL Program: 10.557 Special Supplemental Nutrition Program for Women, Infants, and Children Area: Procurement and Suspension and Debarment Questioned Costs: $1,433 Criteria: 2 CFR 200.302 states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Moreover, the recipient’s and subrecipient’s financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. Conditions: 1. For 2 (or 50%) of four items, aggregating $4,618 of $223,728 expenditures subjected to procurement and suspension and debarment test, no procurement file was provided to substantiate whether the Department of Administration (DOA) complied with applicable procurement requirements for the following: See the Notes to the SEFA for chart/table. 2. Seven initially tested samples were later determined to be procured in prior years and are not procurements during fiscal year 2024. Consequently, remaining samples tested were insufficient to satisfy the minimum number of items to test. Finding No.: 2024-012, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.557 Special Supplemental Nutrition Program for Women, Infants, and Children Area: Procurement and Suspension and Debarment Questioned Costs: $1,433 Cause: DOA’s new financial management system implemented during the fiscal year has no capability to generate a report of all expenditures procured during the fiscal year and expenditure information from the old financial management system are not completely evident from the migrated expenditure information in the new financial management system, hence, there was difficulty in establishing population that will be subjected to procurement and suspension and debarment test. As there was no efficient alternative way of identifying whether or not costs charged to the program were procured during the fiscal year, and due to the timing of the audit and lack of staffing resources, DOA was unable to provide the procurement files of selected transactions by the agreed audit timeline. Effect: GovGuam is in noncompliance with applicable procurement and suspension and debarment requirements. The reportable questioned cost is $1,433 based on the items identified in Condition #1 above. Recommendation: DOA management should ensure that financial management system in place permits the preparation of reports of all expenditures procured during the fiscal year. Responsible personnel should ensure that documentation is adequate to comply with the applicable procurement requirements. Specifically, documentation should indicate the history of procurement, including the solicitation process and rationale for contractors or vendor selection. Views of Responsible Officials: GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. GSA has revised IFB templates to include the required debarment and suspension certification language in accordance with 2 CFR 200.214. Effective immediately, all new contracts will include this clause prior to execution. For local vendors that may not appear in federal systems, GSA will require a debarment and suspension certification as part of the contracting process and maintain this documentation within the procurement record.

Finding No.: 2024-013 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Area: Procurement and Suspension and Debarment Questioned Costs: $4,594,214 Criteria: 2 CFR 200.403(a) states that federal program expenditures should be necessary and reasonable for the performance of the Federal award in accordance with allowable costs/cost principles requirements and 2 CFR 200.403(g) states that costs should be adequately documented. 2 CFR 200.439(b) states that: (1) Capital expenditures for general purpose equipment, buildings, and land are allowable as direct costs, but only with the prior written approval of the Federal agency or pass-through entity. (2) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $10,000 or more have the prior written approval of the Federal agency or pass-through entity. (3) Capital expenditures for improvements to land, buildings, or equipment that materially increase their value or useful life are allowable as a direct cost, but only with the prior written approval of the Federal agency or pass-through entity. 2 CFR 180.300 requires entities entering into a covered transaction with another person at the next lower tier to verify that the person with whom they intend to do business is not excluded or disqualified. Such verification can be made by (a) checking SAM.gov Exclusions, or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. 2 CFR 180.220 (b) (1) states that a contract for goods and services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction covered under 2 CFR 180.210, and the contract amount is expected to equal or exceed $25,000. Finding No.: 2024-013, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Area: Procurement and Suspension and Debarment Questioned Costs: $4,594,214 Criteria, continued: 2 CFR 200.302 states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Moreover, the recipient’s and subrecipient’s financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. Conditions: 1. For four (or 11%) of thirty-eight items, aggregating $7,792,207 of $11,505,805 in total non-payroll expenditures subjected to allowable costs/cost principles compliance test, deficiencies were noted, as follows: See the Notes to the SEFA for chart/table. For item #s 1 through 4, there is no Authorization to Proceed (ATP) document on file to support that expense was approved prior to being incurred. Finding No.: 2024-013, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Area: Procurement and Suspension and Debarment Questioned Costs: $4,594,214 Conditions, continued: 2. For seven (or 88%) of eight items, aggregating $4,061,890 of $4,681,768 of expenditures subjected to procurement and suspension and debarment compliance test, we noted the following: See the Notes to the SEFA for chart/table. For item #s 1 through 3, the General Services Agency (GSA) represented that it performed verification of suspension or debarment from SAM.gov. However, no formal documentation is kept on file to demonstrate compliance at the time of procurement. For item #s 4 through 7, no procurement file was provided to substantiate whether the Department of Administration (DOA) complied with applicable procurement and suspension and debarment requirements. 3. Schedule of Expenditures of Federal Awards (SEFA) was revised subsequently after expenditures were initially determined and tested for suspension and debarment. Based on the revised SEFA, the number of items tested were insufficient to satisfy the minimum required number of items to test. Cause: The Department of Administration (DOA) did not obtain ATP documentation from federal grantor agency as they represented that it is not required since the requirement to obtain such is not explicitly indicated in the grant award. Finding No.: 2024-013, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Area: Procurement and Suspension and Debarment Questioned Costs: $4,594,214 Cause, continued: DOA’s new financial management system implemented during the fiscal year has no capability to generate a report of all expenditures procured during the fiscal year and expenditure information from the old financial management system are not completely evident from the migrated expenditure information in the new financial management system, hence, there was difficulty in establishing population that will be subjected to procurement and suspension and debarment test. As there was no efficient alternative way of identifying whether or not costs charged to the program were procured during the fiscal year, and due to the timing of the audit and lack of staffing resources, DOA was unable to provide the procurement files of selected transactions by the agreed audit timeline. This limitation resulted to repeated replacement of sample selections to meet the minimum sample size required for testing. DOA also does not have a formal policy requiring documentation of procedures performed to verify that the person in a covered transaction with whom they intend to do business is not excluded or disqualified. Effect: GovGuam is in noncompliance with applicable allowable costs/cost principles and procurement and suspension and debarment requirements. The reportable questioned cost related to allowable costs/cost principles requirements based on the items identified in Condition #1 above is $3,850,177. The reportable questioned cost related to procurement and suspension and debarment requirements based on the items identified in Condition #2 above is $4,054,514. Only $4,594,214 total questioned cost is reported at this finding as $3,310,477 is reported and included in both Condition #s 1 and 2 above. Identification as a Repeat Finding: 2023-012 Recommendation: DOA management should obtain clarification from federal grantor agency regarding ATP requirement and/or exemption of capital expenditures of the program. Finding No.: 2024-013, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Area: Procurement and Suspension and Debarment Questioned Costs: $4,594,214 Recommendation, continued: DOA management should ensure that financial management system in place permits the preparation of report of all expenditures procured during the fiscal year. Responsible personnel should ensure that documentation is adequate to comply with the applicable procurement requirements. Specifically, documentation should indicate the history of procurement, including the solicitation process and rationale for contractors or vendor selection. DOA management should establish formal policy requiring retaining documentation of procedures performed to verify that the person in a covered transaction with whom they intend to do business is not excluded or disqualified. Views of Responsible Officials: Agency disagrees with 2 out of the 3 findings. • Condition 1 regarding the Authorization To Proceed (ATP), as per the Grant and Cooperative Agreement and the Grant Terms and Conditions, it did not state that an ATP is required to begin work on the grant for D20AP00048 and D21AP10145.The Government complies with ATP requirements for grants which mandate such compliance. If the grant is silent, no ATP is required.. • Condition 2 GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. • Condition 3 The necessary controls will be strengthened when the updated Federal Grant module is fully implemented. Auditor’s Response: Our finding remains. Although no ATP may be required, the selected samples did not demonstrate compliance related to obtaining the required written pre-approval as mentioned in the criteria above.

Finding No.: 2024-015 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: Various Area: Reporting Questioned Costs: $0 Criteria: 2 CFR 200.302(a) states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 300.302(b) states that recipient’s financial management system must provide for the following: 1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. 2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in 2 CFR 200.328 and 200.329. 3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. 2 CFR 200.328(c) states that recipient must submit financial reports as required by the Federal award. Condition: Bureau of Budget and Management Research (BBMR) was unable to provide a complete listing of financial reports required to be submitted for each of grant awards effective during the fiscal year. Finding No.: 2024-015, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: Various Area: Reporting Questioned Costs: $0 Cause: BBMR did not maintain an internal monitoring of financial reports required to be submitted for each of grant awards effective during the fiscal year and did not ensure compliance with applicable reporting requirements. Effect: We are unable to determine compliance with applicable reporting requirements. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Identification as a Repeat Finding: 2023-013 Recommendation: BBMR management should enforce monitoring controls over compliance with applicable reporting requirements. Responsible personnel should maintain a monitoring of financial reports required to be submitted for each of grant awards effective during the fiscal year. Views of Responsible Officials: BBMR will work with DOA to keep soft copies of submitted and approved Federal Financial Reports (FFR) on hand.

Finding No.: 2024-024 Federal Agency: U.S. Department of the Treasury AL Program: 21.026 Homeowner Assistance Fund Federal Award No.: COVID-19 Section 3206 of the American Rescue Plan Act of 2021 Area: Reporting Questioned Costs: $0 Criteria: In accordance with applicable reporting requirements, GovGuam is required to submit quarterly financial report (PRA 1505-0269-Quarterly) and annual performance report (PRA 1505-0269). 2 CFR 200.302(a) states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 300.302(b) states that recipient’s financial management system must provide for the following: 1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. 2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in 2 CFR 200.328 and 200.329. 3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. 2 CFR 200.329(a) states that recipient is responsible for the oversight of the Federal award. The recipient must monitor its activities under Federal awards to ensure it is compliant with all requirements and meeting performance expectations. Monitoring by the recipient must cover each program, function, or activity. Finding No.: 2024-024, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.026 Homeowner Assistance Fund Federal Award No.: COVID-19 Section 3206 of the American Rescue Plan Act of 2021 Area: Reporting Questioned Costs: $0 Criteria, continued: Per Homeowner Assistance Fund: Annual Report User Guide October 14, 2022 (Updated October 15, 2025), the annual report required to be submitted during fiscal year 2024 is the annual report with period covered October 1, 2022 through September 30, 2023, which is required to be submitted on or before November 15, 2023. Conditions: 1. For three (or 75%) of four financial reports tested, expenditures reported in the quarterly reports differ from amounts per underlying accounting records and no reconciliation was provided to explain the identified variances, as follows: See the Notes to the SEFA for chart/table. 2. For four (or 100%) of four financial reports tested, records that accumulate and summarize reported data/ key line items such as 1) Administrative Expenses; and 2) Services, Counseling & Education were not provided. 3. The annual report with period covered October 1, 2022 through September 30, 2023, which was required to be submitted on or before November 15, 2023 was not provided. Cause: The Department of Administration (DOA) lacks established internal control policies and procedures relating to proper turn-over of documents. DOA was unable to: 1) provide reconciliation to explain the identified variances; 2) provide sufficient supporting records to substantiate the reported data/ key line items; and 3) unable to provide a copy of the annual report. Effect: GovGuam is in noncompliance with applicable reporting requirements. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Finding No.: 2024-024, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.026 Homeowner Assistance Fund Federal Award No.: COVID-19 Section 3206 of the American Rescue Plan Act of 2021 Area: Reporting Questioned Costs: $0 Identification as a Repeat Finding: 2023-016 Recommendation: DOA management should establish internal control policies and procedures over retention of grant-related documents after period of performance for a period specified by the grant terms and conditions. Responsible personnel should review underlying accounting records and perform reconciliation of the required reports. Views of Responsible Officials: The Agency is reviewing its federal grants management to ensure robust handover and succession plans are in place of future programs.

Finding No.: 2024-027 Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Section 9901 of the American Rescue Plan Act of 2021 Area: Procurement and Suspension and Debarment Questioned Costs: $ Undeterminable Criteria: 2 CFR 200.302 states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Moreover, the recipient’s and subrecipient’s financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. Condition: Report of all expenditures procured during the fiscal year could not be provided. Furthermore, there is no efficient and effective alternative way of identifying whether or not costs charged to the program were procured during the fiscal year. Cause: The Department of Administration’s (DOA) new financial management system implemented during the fiscal year has no capability to generate a report of all expenditures procured during the fiscal year and expenditure information from the old financial management system are not completely evident from the migrated expenditure information in the new financial management system. Furthermore, there was no efficient alternative way of identifying whether or not costs charged to the program were procured during the fiscal year. Effect: We are unable to make selection of transactions necessary to provide us with sufficient appropriate audit evidence to support an opinion on compliance with procurement and suspension and debarment compliance requirement. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Finding No.: 2024-027, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Section 9901 of the American Rescue Plan Act of 2021 Area: Procurement and Suspension and Debarment Questioned Costs: $ Undeterminable Identification as a Repeat Finding: 2023-017 Recommendation: DOA management should ensure that financial management system in place permits the preparation of report of all expenditures procured during the fiscal year. Views of Responsible Officials: GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. GSA has revised IFB templates to include the required debarment and suspension certification language in accordance with 2 CFR 200.214. Effective immediately, all new contracts will include this clause prior to execution. For local vendors that may not appear in federal systems, GSA will require a debarment and suspension certification as part of the contracting process and maintain this documentation within the procurement record.

Finding No.: 2024-039 Federal Agency: U.S. Department of Health and Human Service AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Area: Procurement and Suspension and Debarment Questioned Costs: $980,252 Criteria: 2 CFR 180.300 requires entities entering into a covered transaction with another person at the next lower tier to verify that the person with whom they intend to do business is not excluded or disqualified. Such verification can be made by (a) checking SAM.gov Exclusions, or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. 2 CFR 180.220 (b) (1) states that a contract for goods and services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction covered under 2 CFR 180.210, and the contract amount is expected to equal or exceed $25,000. 2 CFR 200.302 states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Moreover, the recipient’s and subrecipient’s financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. Conditions: 1. For thirteen (or 62%) of twenty-one items, aggregating $1,042,567 of $1,799,849 of expenditures subjected to procurement and suspension and debarment test, we noted the following: See the Notes to the SEFA for chart/table. Finding No.: 2024-039, continued Federal Agency: U.S. Department of Health and Human Service AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Area: Procurement and Suspension and Debarment Questioned Costs: $980,252 Conditions, continued: See the Notes to the SEFA for chart/table. For item #s 1 through 4, the General Services Agency (GSA) represented that it performed verification of suspension or debarment from SAM.gov. However, no formal documentation is kept on file to demonstrate compliance at the time of procurement. For items #s 5 through 13, we noted noncompliance with applicable procurement policies and procedures due to various reasons, such as expired procurement contracts, unclear procurement method followed, and lack of rationale for vendor selection. 2. Three initially tested samples were later determined to be procured in prior years and are not procurements during fiscal year 2024. Consequently, remaining samples tested were insufficient to satisfy the minimum number of items to test. Cause: DOA’s new financial management system implemented during the fiscal year has no capability to generate a report of all expenditures procured during the fiscal year and expenditure information from the old financial management system are not completely evident from the migrated expenditure information in the new financial management system, hence, there was difficulty in establishing population that will be subjected to procurement and suspension and debarment test. As there was no efficient alternative way of identifying whether or not costs charged to the program were procured during the fiscal year, and due to the timing of the audit and lack of staffing resources, DOA was unable to provide the procurement files of selected transactions by the agreed audit timeline. Finding No.: 2024-039, continued Federal Agency: U.S. Department of Health and Human Service AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Area: Procurement and Suspension and Debarment Questioned Costs: $980,252 Cause, continued: This limitation necessitated repeated replacement of sample selections to meet the minimum sample size required for testing. DOA also does not have a formal policy requiring documentation of procedures performed to verify that the person in a covered transaction with whom they intend to do business is not excluded or disqualified. Effect: GovGuam is in noncompliance with applicable procurement and suspension and debarment requirements. The reportable questioned cost is $980,252 based on the items identified in Condition #1 above. Identification as a Repeat Finding: 2023-027 Recommendation: DOA management should ensure that financial management system in place permits the preparation of report of all expenditures procured during the fiscal year. Responsible personnel should ensure that documentation is adequate to comply with the applicable procurement requirements. Specifically, documentation should indicate the history of procurement, including the solicitation process and rationale for contractors or vendor selection. DOA management should establish formal policy requiring retaining documentation of procedures performed to verify that the person in a covered transaction with whom they intend to do business is not excluded or disqualified Views of Responsible Officials: GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. GSA has revised IFB templates to include the required debarment and suspension certification language in accordance with 2 CFR 200.214. Effective immediately, all new contracts will include this clause prior to execution. Finding No.: 2024-039, continued Federal Agency: U.S. Department of Health and Human Service AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Area: Procurement and Suspension and Debarment Questioned Costs: $980,252 Views of Responsible Officials, continued: For local vendors that may not appear in federal systems, GSA will require a debarment and suspension certification as part of the contracting process and maintain this documentation within the procurement record.

Finding No.: 2024-048 Federal Agency: U.S. Department of Health and Human Service AL Program: 93.778 Medical Assistance Program Federal Award No.: 75X0512 Area: Eligibility for Individuals Area: Special Tests and Provisions - Utilization Control Area: Special Tests and Provisions - Provider Eligibility (Screening and Enrollment) Area: Special Tests and Provisions - Provider Health and Safety Standards Questioned Costs: $ Undeterminable Criteria: 2 CFR 200.302 states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient and subrecipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Moreover, the recipient’s and subrecipient’s financial management system must provide for maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. Condition: A reconciled medical claims schedule for the fiscal year could not be provided. Specifically, total amount of medical claims per medical claims schedule ($186 million) did not agree with the claims expenditure per financial records ($189 million). Cause: There is a lack of reconciliation process between Department of Public Health and Social Services (DPHSS) and Department of Administration (DOA). Effect: We are unable to establish a complete and accurate population from which to draw our selection of transactions in order to provide sufficient appropriate audit evidence to support an opinion on compliance. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Finding No.: 2024-048, continued Federal Agency: U.S. Department of Health and Human Service AL Program: 93.778 Medical Assistance Program Federal Award No.: 75X0512 Area: Eligibility for Individuals Area: Special Tests and Provisions - Utilization Control Area: Special Tests and Provisions - Provider Eligibility (Screening and Enrollment) Area: Special Tests and Provisions - Provider Health and Safety Standards Questioned Costs: $ Undeterminable Recommendation: Reconciliation process between DPHSS and DOA should take place to ensure that claims expenditure per financial record is supported by underlying medical claims schedule. Views of Responsible Officials: DPHSS agrees with this finding. To address the recommendation for a reconciliation process, DPHSS is in the process of forming a multi-agency technology initiative which will include: • Establishment of an Inter-Agency Data Hub: DPHSS, in collaboration with the Office of Technology (OTECH) and the Department of Administration (DOA), aims to establish a centralized Data Hub. This hub will facilitate real-time or scheduled data synchronization between the DPHSS medical management systems and DOA’s financial accounting records, which are managed in the Guam Financial Management Information System (GFMIS). The data hub is intended to ensure all claims paid are automatically after proper approvals and are then reconciled with the general ledger. • Inter-Agency Agreement and Coordination: DPHSS acknowledges that successful implementation of this Data Hub requires a unified commitment. DPHSS leadership is coordinating with the Director of DOA to discuss the technical requirements and administrative protocols. A formal Memorandum of Agreement (MOA) or a joint standard procedure will be sought, subject to the concurrence and approval by both Agency Directors. • Manual Interim Reconciliation: Until the Data Hub is fully operational, DPHSS will work with DOA to implement a monthly manual reconciliation process. This will involve a “crosswalk” review of claim batch totals against financial system postings to identify and resolve variances (such as voided checks or manual adjustments) in a timely manner. • Engagement with OTECH: Once the two directors agree on the framework, DPHSS will engage OTECH to design the data architecture necessary to ensure data integrity, security, and compliance with federal reporting standards. Estimated implementation timeframe: March 31, 2027

Finding No.: 2024-052 Federal Agency: U.S. Department of Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: Various Area: Reporting Questioned Costs: $0 Criteria: 2 CFR 200.302(a) states that each State must expend and account for the Federal award in accordance with State laws and procedures for expending and accounting for the State’s funds. All recipient financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by the terms and conditions; and tracking expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 300.302(b) states that recipient’s financial management system must provide for the following: 1) Identification of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number, year the Federal award was issued, and name of the Federal agency or pass-through entity. 2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in 2 CFR 200.328 and 200.329. 3) Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. 2 CFR 200.328(c) states that recipient must submit financial reports as required by the Federal award. Conditions: 1. We are unable to establish a complete list of financial reports required to be submitted during the fiscal year as Guam Homeland Security (GHS) was unable to provide copies of each grant award. GHS was unable to demonstrate that the financial reports submitted to our audit team consisted of all the required reports. Finding No.: 2024-052, continued Federal Agency: U.S. Department of Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: Various Area: Reporting Questioned Costs: $0 Conditions, continued: 2. From the list of reports submitted to our audit team, for eight (or 100%) of eight reports tested, records that accumulate and summarize reported data such as 1) cash receipts; 2) cash disbursements; and 3) federal share of expenditures, were not provided for the following: See the Notes to the SEFA for chart/table. Cause: Department of Administration (DOA) assigned GHS as the agency responsible for providing required audit documentation, however, GHS did not provide timely responses to the audit team’s requests. GHS could not identify the personnel responsible for compliance with applicable reporting requirements. Effect: We are unable to determine compliance with applicable reporting requirements. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Recommendation: GHS management should enforce monitoring controls over compliance with applicable reporting requirements. Responsible personnel should maintain a monitoring of financial reports required to be submitted for each grant award effective during the fiscal year. Finding No.: 2024-052, continued Federal Agency: U.S. Department of Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: Various Area: Reporting Questioned Costs: $0 Views of Responsible Officials: GHS will work with DOA to make sure reports are submitted on time. GHS will also retain documentation of submitted reports.

Duplicate Payments to Vendors Type of Finding Material Weakness - Internal Control Over Financial Reporting Material Noncompliance - Material to the Financial Statements Material Weakness - Internal Control Over Compliance Material Noncompliance - Material to the Major Program New or Repeat Finding New Federal Program Community Development Block Grant/State's Program (ALN 14.228) Federal Agency U.S. Department of Housing and Urban Development Pass-through Entity and Identifying Number(s) Texas General Land Office (22-119-003-D373, 22-085-017-D253) Compliance Requirement(s) A. Activities allowed or unallowed B. Allowable costs/cost principles Criteria 2 CFR 200.303(a) requires entities to maintain effective internal control over federal awards. 2 CFR 200.302(b)(3) requires entities to maintain accountability over funds to ensure they are used for authorized purposes and safeguarded against loss or misuse. Condition The City paid a vendor twice for the same invoices and also submitted duplicate reimbursement requests to the pass through entity for the same expenditures. These errors resulted in a material misstatement of expenditures recorded in the City’s accounting records and in federal reimbursement requests. Cause The same individual entered invoices and released them for payment without secondary review. Inconsistent invoice naming prevented the accounting system’s duplicate invoice controls from identifying previously processed and paid invoices. Effect or Potential Effect Duplicate payments may occur or go undetected, and duplicate reimbursement requests may be submitted to the grantor. Questioned Costs $721,272 Context During the audit period, the City experienced significant turnover within the finance department. Reduced staffing and inconsistent invoice entry practices prevented system controls from recognizing duplicate invoices, resulting in duplicate vendor payments. Because the City relied on these records when requesting grant reimbursements, duplicate requests were also submitted. The errors were identified by the auditors and corrected by the City prior to September 30, 2024. Recommendation The City should segregate duties so one individual enters invoices and another reviews and releases payments. The City should also adopt a standardized invoice naming convention to allow system controls to identify potential duplicates. Views of Responsible Officials City management agrees with the finding. Duplicate payments and reimbursement requests occurred during a period of financial department turnover, compounded by insufficient segregation of duties and inconsistent invoice referencing. The City has recovered the duplicate payments, returned the duplicate reimbursements, implemented a standardized invoice numbering convention, and revised procedures to ensure appropriate review before payments are released. Management is also evaluating additional system controls to prevent recurrence.

We identified a material weakness in internal control over compliance related to allowable / unallowable cost requirements for excess drawdowns beyond 8% rate for the REAP program. Criteria: Under 2 CFR 200.414, indirect costs are recovered by applying an approved indirect cost rate to the appropriate base, generally modified total direct costs (MTDC), rather than by drawing the budgeted indirect cost amount. Nonfederal entities must maintain effective control over and accountability for all funds and ensure they are used solely for authorized purposes (2 CFR 200.302). Federal funds are to be drawn only as needed to meet immediate cash requirements for the federal award, minimizing the time between transfer from the U.S. Treasury and disbursement by the Center (2 CFR 200.305). In addition, the Center’s written Indirect Cost Rate Policy requires that indirect costs be applied as a percentage of MTDC, defines the MTDC base (including and excluding specific cost categories), and assigns responsibilities to finance and compliance personnel for ensuring proper calculation, monitoring, documentation, and reporting of indirect costs on federal awards. The policy also requires ongoing monitoring of the correct application of the indirect cost rate to MTDC and retention of supporting documentation for audit and review. Condition: For the Year 1 period of performance under the REAP award, the Center drew down the entire indirect cost budget of $625,013 included in the $8,437,681 Grant Award Notification (GAN), rather than limiting indirect cost draws to the amount calculated by applying the approved 8 percent indirect cost rate to the actual MTDC base. Total expenditures drawn for the period were $6,489,490, which included the full $625,013 of indirect costs. Some drawdowns applied the 8 percent rate to the MTDC base, while other drawdowns exceeded the amount supportable by the rate in order to reach the full budgeted indirect cost. Although the Center has an Indirect Cost Rate Policy that describes how the indirect cost rate is to be applied to MTDC and requires monitoring of the correct application of the rate, the procedures described in that policy were not effectively implemented or followed for this award.There is also an element in which training stipends need to be removed before calculating the allowable indirect cost amount. The Center has stipends that could related to the MTDC based on a template provided by the US Department of Education. Because of the clarity of how these stipends are undefined, this could further impact the calculation. Based on our recalculation, this resulted in approximately $155,875 of indirect costs drawn in excess of the allowable amount under the approved rate and MTDC base. This constitutes noncompliance with the award terms and the Uniform Guidance requirements for charging indirect costs and drawing federal funds based on actual allowable costs incurred. Cause: This was the Center’s first federal award. Management inadvertently misunderstood how to apply the approved indirect cost rate and believed it was appropriate to draw the full indirect cost amount budgeted in the GAN, rather than calculating indirect costs by applying the 8 percent rate to the actual MTDC base. While the Center has an established written Indirect Cost Rate Policy that is consistent with federal requirements and clearly describes the application of the rate to MTDC, the policy was not fully operationalized for this award. Specifically, staff responsible for drawdowns did not consistently follow the policy’s procedures for calculating indirect cost based on MTDC, monitoring the correct application of the rate, and retaining calculation worksheets; and there was no documented supervisory review to ensure compliance with both the policy and the Uniform Guidance prior to submitting drawdown requests. Also, the US Department of Education’s template that demonstrated for training stipend costs as a reduction has not been considered fully based on the definition of those costs. Effect or Potential Effect: By drawing down approximately $155,875 more than the allowable indirect costs for the period, the Center used federal funds in excess of what was permitted under the approved indirect cost rate and MTDC base. These excess draws represent costs that may be disallowed by the U.S. Department of Education and may require repayment. Continued reliance on budgeted indirect amounts, rather than applying the rate to the MTDC base in accordance with both the Uniform Guidance and the Center’s Indirect Cost Rate Policy, increases the risk of further over- or under-recovery of indirect costs and noncompliance with cash management requirements.Questioned Costs: We calculated questioned costs of $155,875 representing the excess of indirect costs drawn over the amount that would have been allowable had the approved 8 percent indirect cost rate been applied to the actual MTDC base for the period. This does not include the potential impact of training stipend costs being excluded in arriving at the allowable indirect cost. Because the questioned costs exceed $25,000, they are required to be reported in the Schedule of Findings and Questioned Costs. At the time of our audit, no portion of the $155,875 had been repaid, and the federal agency had not yet issued a determination regarding the resolution of these questioned costs. Perspective: The total Year 1 GAN amount was $8,437,681, including $625,013 of budgeted indirect costs. During the audit period, the Center drew down $6,489,490 in total, including the full $625,013 of indirect costs. The issue affected multiple drawdowns during the period; some draws were calculated at the approved 8 percent rate, while others either did not exceeded the amount supported by the rate to enable drawing the full budgeted indirect costs. The existence of a written Indirect Cost Rate Policy that was not consistently followed, combined with the pattern of excess indirect draws, indicates a systemic implementation and monitoring issue rather than an isolated error. Recommendation: We recommend that management: 1. Recalculate allowable indirect costs for the period by applying the approved 8 percent indirect cost rate to the actual MTDC base and work with the U.S. Department of Education to resolve the $155,875 in questioned costs, including returning any unallowable amounts as required. This includes ascertaining that training stipends, if applicable by definition, are excluded from total direct cost before the 8% multiplier is applied. 2. Fully implement and operationalize the existing Indirect Cost Rate Policy by: • Ensuring that the MTDC base is correctly determined for this and future awards and that the approved indirect cost rate is applied only to that base; • Requiring preparation and retention of indirect cost calculation worksheets that tie to MTDC and support each drawdown; and • Establishing a documented supervisory review to verify that indirect costs are calculated and drawn in accordance with the Indirect Cost Rate Policy, the GAN, and the Uniform Guidance prior to submission of drawdown requests.Provide targeted training to finance and program staff on the Indirect Cost Rate Policy, including the definition of MTDC, the appropriate application of the indirect cost rate, and the monitoring and documentation requirements described in the policy, to reinforce the otherwise sound policy framework already in place. Views of Responsible Officials: Management agrees with the finding. As this was the Center’s first federal award, management misunderstood the proper application of the approved indirect cost rate for this program and drew the full budgeted indirect cost amount instead of applying the rate to the MTDC base. Management notes that it has adopted an Indirect Cost Rate Policy that is intended to ensure consistent, compliant application and monitoring of indirect costs across federal awards; however, this policy was not consistently followed for the REAP award. Management plans to recalculate allowable indirect costs, consult with the U.S. Department of Education regarding resolution of the $155,875 in questioned costs, and strengthen implementation of its Indirect Cost Rate Policy through enhanced procedures, documentation, supervisory review, and staff training to ensure that future indirect cost calculations and drawdowns comply with both the policy and the Uniform Guidance.

Criteria: 2 CFR §200.328 and §200.302 provides that recipients of Federal awards must submit performance and financial reports in a timely manner, ensure reports are accurate and reconcilable to financial records, and maintain documentation of control activities, including review procedures. Condition: The Organization was unable to provide sufficient documentary evidence that reports were reviewed and approved prior to their submission to Federal agencies. Cause: There has been a substantial number of new hires as well as turnover of management personnel throughout various levels of the Organization, which has partially delayed the planned implementation of control activities that would facilitate supervisory review and approval of all financial and performance reports submitted to Federal funding agencies. Effect: Required performance and financial reports were not submitted to Federal agencies on a timely basis throughout the year. This indicates that identified controls over the Organization’s compliance with the Uniform Guidance special tests and provisions requirements regarding performance and financial reporting are not properly designed and implemented. Questioned Costs: None Context: We performed procedures to test the Organization’s reporting practices related to federal awards. We selected a sample of required financial and performance reports submitted to federal awarding agencies for testing. The objective was to verify whether reports were submitted timely, accurately reflected accounting data, and included evidence of management review. During the testing, we were unable to obtain sufficient and appropriate documentary evidence to corroborate the Organization’s compliance with reporting requirements. We noted that some reports were not submitted before the stated deadline. In addition, substantial adjustments were required to reconcile some of the amounts reported to the Federal awarding agencies with the Organization’s accounting records. Recommendation: We recommend that management establishes and implements policies that provide for documentary evidence of supervisory review of reports required by Federal agencies to ensure the timely submission of accurate reports throughout the year. Additionally, we recommend that the management establishes control activities to facilitate the reconciliation of data reported to Federal awarding agencies to the Organization’s underlying accounting records. Views of Responsible Officials: See management’s view and corrective action plan at the end of this report.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Aging Cluster ALN: 93.044 93.045 93.053 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2201TXOACM 10/1/2021 – 9/30/2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of six SF-425 reports submitted during the fiscal year. For the March 31, 2024, report for the 2201TXOACM award, audit procedures included comparing the reported amounts to the general ledger. We noted the following variances: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None. Context: See “Condition.” Cause: Amounts in the supporting general ledger documentation were accurate. However, the corresponding line items on the SF-425 report were not reported accurately. Management did not revise the March 31, 2024, report as the report is cumulative and the final report for the 2201TXOACM grant will include the corrected amounts. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No. Recommendation: We recommend management reconcile all amounts reported on the SF-425 reports to the general ledger or other supporting documentation to ensure completeness and accuracy prior to submission. Views of responsible officials: HHSC concurs with the finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Reporting – Financial Reporting Federal Agency: U.S. Department of Transportation Federal Program Title: Airport Improvement program ALN: 20.106 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 3-48-SBGP-147-2022 September 14, 2022 – September 13, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Department of Transportation (TXDOT): Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TXDOT is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.328(c), the recipient or subrecipient must submit financial reports as required by the Federal award. Per 2 CFR 200.302(b)(2), the recipient's and subrecipient's financial management system must provide for the following: accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. Condition: Audit procedures included a sample of five SF-425, Federal Financial Reports submitted during the fiscal year. For the SF-425 report for the 3-48-SBGP-147-2022 grant award submitted on March 6, 2024, we noted TXDOT did not report the recipient share of expenditures required. The recipient share of expenditures was incurred for the project; however, they were inadvertently omitted from the report. Questioned costs: None Context: See “Condition.” Cause: TXDOT prepares financial reports based on expenditures reported in its Peoplesoft system. The project for grant 3-48-SBGP-147-2022 was set up as 100% federal as the match was being met by the subrecipient. As such, TXDOT was reimbursing the subrecipient at 100% while the subrecipient met the 10% match with local funds. Accordingly, the matching funds, as incurred by the subrecipient, were not considered when preparing and reviewing the SF-425 report. Effect: Improperly designed internal controls over reporting may result in a misstatement of amounts reported on federal reports. Repeat Finding: No Recommendation: We recommend management enhance its internal controls over the review and approval of the SF-425 reports to include a review of the grant award to ensure the subrecipient share of expenditures are reported properly reported. Views of responsible officials: TxDOT AVN agrees with this finding.

Criteria: Under 2 CFR §200.302(b), §200.303, and §200.305, non-federal entities must establish internal controls over federal awards to ensure proper financial management, allowability of costs, timely and accurate reporting, and proper cash management. Additionally, under GAAP (ASC 958-605), grant revenue should be recognized when allowable costs have been incurred. Documentation and supervisory review are necessary to support revenue recognition and ensure expenditures and drawdowns are accurately reported. Condition: The Organization did not document a monthly reconciliation review process to confirm that federal revenues recorded in the general ledger and federal grant drawdowns were supported by allowable costs incurred. Additionally, there was no evidence of review or reconciliation of annual SF-425 Federal Financial Reports to verify that cumulative drawdowns reconciled to allowable costs and recorded revenue. Cause: The Organization lacked a formal internal control process requiring review and sign-off of the reconciliation of grant expenditures, grant revenue, drawdowns, and SF-425 federal financial reporting. Effect: Inadequate internal controls over allowable costs, cash management, and federal financial reporting increased the risk of improper grant revenue recognition recorded, expenditures not being accurately reported, and unallowable costs being claimed, which could lead to misstatements in the financial statements, Schedule of Expenditures of Federal Awards (SEFA), and required federal reports, and result in noncompliance with Uniform Guidance and GAAP. Questioned Cost: None Recommendation: Implement a documented monthly reconciliation process to verify that federal revenues recorded and drawn down are supported by allowable costs incurred in accordance with grant terms. Include supervisory review of SF-425 reports and supporting schedules to confirm alignment with recorded expenditures and revenues. Reconciliations should be reviewed and signed by the CFO and retained in grant records to ensure compliance with Uniform Guidance and GAAP.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2024 Comment # 2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP and CSLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The closeout process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2024. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, state filings, etc.). Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). Accordingly, the Agency is not in compliance with federal and state reporting as specified by grants and contracts and the Federal Audit Clearinghouse. The systemic cause appears to be the untimely resignation of key personnel, a change in the accounting system, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Policies and procedures are not followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency has hired a new fiscal officer (CFO) and should hire additional staff (grant accountant and a general ledger accountant) to assist the new fiscal officer. New staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2025.

Criteria: Under 2 CFR §200.302(b), §200.303, and §200.305, non-federal entities must establish internal controls over federal awards to ensure proper financial management, allowability of costs, timely and accurate reporting, and proper cash management. Additionally, under GAAP (ASC 958-605), grant revenue should be recognized when allowable costs have been incurred. Documentation and supervisory review are necessary to support revenue recognition and ensure expenditures and drawdowns are accurately reported. Condition: The Organization did not document a monthly reconciliation review process to confirm that federal revenues recorded in the general ledger and federal grant drawdowns were supported by allowable costs incurred. Additionally, there was no evidence of review or reconciliation of annual SF-425 Federal Financial Reports to verify that cumulative drawdowns reconciled to allowable costs and recorded revenue. Cause: The Organization lacked a formal internal control process requiring review and sign-off of the reconciliation of grant expenditures, grant revenue, drawdowns, and SF-425 federal financial reporting. Effect: Inadequate internal controls over allowable costs, cash management, and federal financial reporting increased the risk of improper grant revenue recognition recorded, expenditures not being accurately reported, and unallowable costs being claimed, which could lead to misstatements in the financial statements, Schedule of Expenditures of Federal Awards (SEFA), and required federal reports, and result in noncompliance with Uniform Guidance and GAAP. Questioned Cost: None Recommendation: Implement a documented monthly reconciliation process to verify that federal revenues recorded and drawn down are supported by allowable costs incurred in accordance with grant terms. Include supervisory review of SF-425 reports and supporting schedules to confirm alignment with recorded expenditures and revenues. Reconciliations should be reviewed and signed by the CFO and retained in grant records to ensure compliance with Uniform Guidance and GAAP.