Findings Citing § 200.303

2025-003 Reporting – PR29 CDBG Cash on Hand Quarterly Report Prior Year Finding Number: N/A Year of Finding Origination: 2025 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.218 Community Development Block Grants/Entitlement Grants Award Number and Year: B-20-MC-27-003, 2020; B-20-MW-27-003, 2020; B-21-MC-27-0003, 2021; B-22-MC-27-0003, 2022; B-23-MC-27-0003, 2023; B-24-MC-27-0003, 2024; B-25-MC-27-0003, 2025 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The PR29 – CDBG Cash on Hand Quarterly Report is a required report. The basis of accounting described in the directions is the cash basis. The instructions also state that program income received by the grantee from the beginning date of the reporting period through the end date of the reporting period should be reported under line 8 of the report. Condition: In the sample of two quarterly PR29– CDBG Cash on Hand Quarterly Reports tested, errors were noted in both reports resulting from the City reporting program income as received during the reporting period when it was applied to a project, not when it was received by the City. Questioned Costs: None. Context: The PR29 – CDBG Cash on Hand Quarterly Report is not used to claim reimbursement of federal funds. The population consisted of four PR29 – CDBG Cash on Hand Quarterly Reports submitted during the fiscal year. The sample size of two was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City of Minneapolis is not in compliance with the reporting requirements for the PR29 – CDBG Cash on Hand Quarterly Reports. Cause: The PR29 – CDBG Cash on Hand Quarterly Reports were prepared by a new employee. The new preparer was following earlier guidance provided to the previous preparer by HUD. Recommendation: We recommend that the City of Minneapolis implement procedures to complete reports as required by HUD in its instructions for the preparation of the PR29 – CDBG Cash on Hand Quarterly Report. View of Responsible Official: Acknowledge

2025-002 Reporting – Federal Funding Accountability and Transparency Act (FFATA) Prior Year Finding Number: N/A Year of Finding Origination: 2025 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.218 Community Development Block Grants/Entitlement Grants 14.218 COVID-19 – Community Development Block Grants/Entitlement Grants Award Number and Year: B-24-MC-27-0003, 2024; B-25-MC-27-0003, 2025 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in Title 2 U.S. Code of Federal Regulations, Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) or SAM.gov. Title 2 U.S. Code of Federal Regulations, Appendix A to Part 170, requires reporting a subaward, once issued, by the end of the subsequent month. Condition: The six subawards issued for the 2025 Community Development Block Grant (CDBG) award with obligation action dates between June 3, 2025, and December 18, 2025, were submitted to SAM.gov on March 23, 2026, after the documentation was requested for the audit. For one of the six subawards tested, the amount in SAM.gov did not agree with the applicable grant agreements or other supporting documentation. Additionally, two subawards for the 2024 CDBG award and one subaward for the 2024 CDBG-CV award were not submitted to either the FSRS or to SAM.gov as of the date of our review. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect 6 3 6 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect $ 1,699,034 $ 340,536 $ 1,699,034 $ 100,000 Questioned Costs: None. Context: The agreement between the Department of Housing and Urban Development (HUD) and the City of Minneapolis for CDBG for the 2025 award year was not signed until December 2025. The City could not submit FFATA subaward reports before the grant was uploaded into SAM.gov by HUD. All six subawards totaling $1,699,034 issued from the 2025 award year were tested. The subawards not reported for 2024 were not considered tested. Effect: The City of Minneapolis is not in compliance with FFATA reporting requirements. Cause: The submittal of the 2025 subawards was overlooked by City staff until the information related to those subawards was requested for the audit. The City was unable to determine the cause of the subaward amount not matching the grant agreement for the subaward. The subawards not submitted for the 2024 award year were due to these subawards not being communicated properly to the preparer of the subaward reports. The CDBG-CV subaward report was not submitted due to being an amendment to replace an initial award using Emergency Solutions Grant Program funds with CDBG-CV funds. The City did not want to overstate the total HUD funds provided to the subrecipient and were unaware that subaward reports could be edited. Recommendation: We recommend the City of Minneapolis implement procedures to ensure subawards are submitted as required by FFATA. View of Responsible Official: Concur

Program: COVID-19 Community Development Block Grant Cluster Entitlement/Special Purpose Grants Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B23-MC-20-0004 and 2023, B24-MC-20-0004 and 2024, B-25-MC-20-0004 and 2025 Program: COVID-19 Housing Voucher Center Cluster Federal Financial Assistance Listing Number: 14.871, 14.879 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: KS004VO0127 and 2025, EHV KS004 and 2025, KS004DV0001 and 2025 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, state that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing, we identified the following instances where the timesheet was not reviewed and approved by the employee’s supervisor: • One (1) timesheet charged to the Community Development Block Grant (CDBG) program • Two (2) timesheets charged to the Housing Voucher Center Cluster (HVC) Cause: The City's internal control procedures permitted certain timesheets to be processed without documented supervisory approval. Effect: Because the City's internal control procedures permitted an exception to documented supervisory approval for the timesheets tested, evidence of review and approval was not available. As a result, the operation of the review control could not be verified for those timesheets.Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of forty (40) timesheets were selected for testing for the CDBG program. A nonstatistical sampling or forty (40) timesheets were selected for testing for the HVC program. The condition above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No Recommendation: We recommend that management strengthen controls over payroll processing by ensuring that all timesheets charged to federal programs are reviewed and approved by an independent supervisor prior to payroll processing. Management should also periodically monitor compliance to confirm that approval controls are operating as designed. View of Responsible Officials: See separately issued Corrective Action Plan.

Program: COVID-19 Community Development Block Grant Cluster Entitlement/Special Purpose Grants Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B23-MC-20-0004 and 2023, B24-MC-20-0004 and 2024, B-25-MC-20-0004 and 2025 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, state that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition: During our testing of the City’s compliance with reporting requirements, we noted four (4) PR-29 reports, where there was no evidence of the Housing Finance Manager’s review and approval prior to the report being submitted. Cause: The City's control procedures did not require documentation to be retained evidencing management review and approval of PR29 reports prior to submission. Effect: Although management indicated that an informal review occurred prior to submission, the control did not require retention of documentation evidencing the review. Consequently, the City could not demonstrate that supervisory review was performed for the reports tested.Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of four (4) of eight (8) PR-29 reports were selected. The condition above was identified during our testwork of the City’s internal controls over reporting. Repeat Finding from Prior Years: No Recommendation: We recommend the City adhere to their policies and ensure the review and approval of reports are documented. View of Responsible Officials: See separately issued Corrective Action Plan.

2025-001 Equipment and Real Property Management Prior Year Finding Number: N/A Year of Finding Origination: 2025 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.218 Community Development Block Grants/Entitlement Grants Award Number and Year: B-25-MC-27-0002, 2025 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.313 (d) states that regardless of whether the equipment is acquired in part or its entirety under the federal award, the recipient or subrecipient must manage equipment (including replacement equipment). Specifically, Title 2 U.S. Code of Federal Regulations § 200.313 (d)(1) states that property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the federal award identification number (FAIN)), the title holder, the acquisition date, the cost of the property, the percentage of the federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Condition: The City of Duluth maintains a listing of equipment acquired with Community Development Block Grants/Entitlement Grant (CDBG) funds; however, the listing does not include all information required by Title 2 U.S. Code of Federal Regulations § 200.313 (d)(1). In the sample of six items tested from the CDBG equipment listing, one of the items tested was no longer in use. A review of the City’s governmental capital asset listing disclosed $142,000 of City park improvements partially funded from the 2016, 2017, and 2018 CDBG projects that were not listed on the CDBG equipment listing. Questioned Costs: Undetermined. Elements of the missing information, such as serial number and location, are not quantifiable as costs. Context: The City of Duluth maintains a listing of equipment; however, the listing does not include the serial number or other identification number, the FAIN, who holds title (City or subrecipient), acquisition date, the percentage of federal award participation, or the disposition data, including the date of disposal and sales price of the property, nor is the City’s CDBG equipment listing complete. The City’s CDBG equipment listing included 19 items totaling $518,355; a sample of six items totaling $178,885 was tested. The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City of Duluth is not in compliance with Title 2 U.S. Code of Federal Regulations §§ 200.313 (d) and (d)(1). Cause: Oversight by City staff. Recommendation: We recommend the City of Duluth implement procedures to ensure the equipment and real property listing includes all the required information. The City should also implement procedures to identify asset additions and disposals to ensure that they are properly identified, recorded, maintained, and safeguarded. View of Responsible Official: Concur

2025-002 Reporting – Federal Funding Accountability and Transparency Act (FFATA) Prior Year Finding Number: N/A Year of Finding Origination: 2025 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Housing and Urban Development Program: 14.218 Community Development Block Grants/Entitlement Grants Award Number and Year: B-24-MC-27-0002, 2024 and B-25-MC-27-0002, 2025 Pass-Through Agency: N/A – Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in Title 2 U.S. Code of Federal Regulations, Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) or SAM.gov. Title 2 U.S. Code of Federal Regulations, Appendix A to Part 170, requires reporting a subaward, once issued, by the end of the subsequent month. Condition: In the sample of four transactions selected from the 2025 submitted FFATA subawards, two subawards were not submitted by the due date. One of these subaward reports was incorrectly entered in SAM.gov. Additionally, one sub-award issued during 2025 relating to the 2024 award year in the amount of $78,300, was not submitted in SAM.gov. Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect 4 1 2 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect $ 505,480 $ 78,300 $ 75,480 $ 30,000 Questioned Costs: None. Context: For the subaward not reported, a subrecipient requested that safety improvements be incorporated in a City road project and requested federal funding from the City to pay for those improvements. The City originated an award in the amount of $78,300, provided federal funding to the subrecipient, and made the safety improvements. The subrecipient then reimbursed that funding to the City. For the two reports not reported timely, these were due in late January 2026 but were submitted a month late. For the subaward reported for the incorrect amount, the amount submitted to SAM.gov was $30,000 but the subaward was issued for $25,000 and, therefore, would be exempt from FFATA reporting requirements. The population included nine subawards reported in 2025 totaling $959,480, with the sample of four subawards totaling $505,480. The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The City of Duluth is not in compliance with FFATA reporting requirements. Cause: The subaward not reported by the City was omitted from FFATA reporting under the mistaken assumption that the reimbursement received from the subrecipient exempted the transaction from compliance. City staff reported they had difficulties in January 2026 with accessing the SAM.gov website which delayed the submission of the subaward reports until February 27, 2026. The incorrect subaward in SAM.gov was the result of an entry error; the submissions to SAM.gov are not reviewed. Recommendation: We recommend the City of Duluth implement procedures to ensure reports are submitted as required by FFATA. View of Responsible Official: Concur

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Identification of the Federal Programs: As this is an indirect cost allocation finding, all Population Services International (PSI) awards on the SEFA are impacted. See Schedule of Findings and Questioned Costs for table. Criteria or Specific Requirement: In accordance with §200.303 Internal Controls, a non-federal entity must (a) establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, §200.475(e) Travel costs, states that airfare costs in excess of the basic least expensive unrestricted accommodations class offered by commercial airlines are unallowable except when such accommodations would: (i) require circuitous routing; (ii) require travel during unreasonable hours; (iii) excessively prolong travel; (iv) result in additional costs that would offset the transportation savings; or (v) offer accommodations not reasonably adequate for the traveler's medical needs. The recipient or subrecipient must justify and document these conditions on a case-by-case basis for the use of first-class or business-class airfare to be allowable in such cases. Condition: HealthXP has documented policies and internal controls over allowability of expenditures incurred. However, as identified below, the review and approval process did not operate effectively. During our testing of the indirect cost pool, we identified one unallowable unapproved expense out of 25 samples tested. The exception involved a business-class airfare totaling $5,930, which does not comply with 2 CFR §200.475, Travel costs. Questioned Costs: Known questioned costs associated with the business class airfare totaled $5,930. Context: This is a condition identified per review of HealthXP’s compliance with allowability and allocability provisions of the Uniform Guidance. The prevalence of this finding is detailed in the condition section above. Samples were selected using a non-statistical method. Cause: HealthXP has documented expenditure policies and procedures regarding the review and approval of expenditures incurred. However, as identified above, the review and approval process for the sample identified above did not operate effectively. Effect: Because this unallowable amount was included in the indirect cost pool allocated across all federal programs, this noncompliance affects all PSI federal awards listed on HealthXP’s Schedule of Expenditures of Federal Awards for the year ended December 31, 2025. Repeat Finding: This is not a repeat finding. Recommendation: We recommend HealthXP adhere to documented policies and procedures regarding review and approval of expenditures. Views of Responsible Officials: HealthXP management agrees with the finding and recommendations set forth within and will provide additional training to staff members to ensure compliance with established policies and procedures. Refer to management’s corrective action plan for additional information.

Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Identification of the Major Federal Program: U.S. Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Grant Award Number under the Uniform Guidance Requirements: See Schedule of Findings and Questioned Costs for table. Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Subaward Reporting in SAM.gov. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: We tested HealthXP’s compliance with specific FFATA reporting requirements. Of the six sub-award reports selected for testing, three of the reports with subaward amounts totaling $668,694 were not submitted within the required timeframe. Specifically, the three FFATA reports were filed between 5 and 36 days later than the required filing date. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of HealthXP’s compliance with specified requirements. The samples were selected using a non-statistical sampling method. Cause: Although HealthXP has existing internal control policies and procedures ensuring appropriate filing of sub-award information in SAM.gov, it failed to file the FFATA reports on time. Effect: Failure to report subrecipient information in a timely manner can result in lack of transparency and accountability, which is contrary to the intent of FFATA. Such non-compliance also increases the risk of loss of future awards if compliance with the provisions of Uniform Guidance is not met. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that all FFATA reports are filed in a timely manner. In addition, management should strengthen the existing internal controls and conduct refresher training to personnel emphasizing timely submission of FFATA reports. Views of Responsible Officials: HealthXP management agrees with the finding and recommendations and will enhance the processes around timely submission of FFATA reports.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2505MN5ADM - 2025 Pass-Through Agency: Minnesota Department of Human Services Award Period: January 1, 2025, through December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County and the Minnesota Department of Human Services (DHS) have a contract surrounding the federal funds. This contract has several obligations and reporting requirements the County must follow. In the guidance from the State of Minnesota provided the County must maintain controls over eligibility verification requirements. Condition: During our testing, we noted the County had a casefile that had listed citizenship verification as “No” within the system which would indicate that no citizenship had been verified. Note that although citizenship had been verified and a copy of the verification was retained, it was not properly completed within the Maxis system. Questioned costs: None Context: During our testing, it was noted that 1 of 40 tested did not have proper eligibility verification documentation within the Maxis system. Cause: The County’s controls were not sufficient to ensure that verification was properly updated within the Maxis system. Effect: The documentation within the maxis system does not accurately reflect the eligibility verification that has been performed. Repeat Finding: No Recommendation: We recommend the County design controls to ensure an adequate review process is in place to ensure all verification procedures are accurately documented. Views of responsible officials: There is no disagreement with the audit finding.

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.696 Certified Community Behavioral Health Clinic Expansion Grant Reporting Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our testing, we identified instances where the annual reports submitted had inaccurate information and incomplete documentation of review and approval prior to submission. Cause: Fraser’s internal controls did not operate as designed, which resulted in inaccurate reports being submitted. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: None reported. Context/Sampling: Both annual reports were reviewed in testing. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive and documented review over reporting prior to submission. Views of Responsible Officials: Management agrees with this finding.

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.696 Certified Community Behavioral Health Clinic Expansion Grant Cash Management Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our testing, we identified an instance where the reimbursement request had inaccurate information and incomplete documentation of review and approval prior to submission of the request. Cause: Fraser’s internal controls did not operate as designed, which resulted in an inaccurate reimbursement request being submitted. Effect: Inadequate internal controls over compliance could result in noncompliance with the federal program. Questioned Costs: $761.08 Context/Sampling: A nonstatistical sample of three out of eleven were selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend that management develop a more extensive and documented review over reimbursement requests prior to submission. Views of Responsible Officials: Management agrees with this finding.

Assistance Listing Number, Federal Agency, and Program Name - 66.616 - U.S. Environmental Protection Agency - Environmental and Climate Justice Community Change Grants Program Federal Award Identification Number and Year - 2024-00E04015 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The Federal Funding Accountability and Transparency Act (FFATA) as mended by Section 6202 of Public Las 110-252 requires recipients of federal awards to report data using the FFATA Subaward Reporting System (FSRS) Tool (pre-March 8, 2025) or SAM.gov (post-March 8, 2025). 2 CFR 200.303 requires that recipients and subrecipients receiving federal awards establish, document, and maintain effective internal control over the federal awards that provide reasonable assurance that the recipient or subrecipient is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition - While the System had controls over accumulating the data for inputs into the portal, it did not have an adequate control in place to ensure transactions subject to FFATA reporting were reviewed for completeness and accuracy upon submission. If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - The System's internal controls over FFATA reporting were not designed to review submissions of FFATA reports. The System did not have a formal review process to verify the completeness and accuracy of data submitted to SAM.gov, nor did it maintain a reconciliation between the accounting system's subaward records and the information entered into SAM.gov. There were no instances of noncompliance or questioned cost identified related to this lack of control. Cause and Effect - The System has not developed or implemented a review structure over the FFATA reporting process at the time of submission. As a result, the System was at increased risk of submitting inaccurate, incomplete, or untimely FFATA reports. Recommendation - The System should implement controls regarding review of prepared FFATA submissions to ensure that all required subaward data is accurately and timely reported to SAM.gov. Views of Responsible Officials and Planned Corrective Actions - Management concurs with this recommendation. MetroHealth will establish and maintain a log documenting FFATA report submission, with internal reviews of disclosures prior to submission.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 232MN101S2514 – 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55250010 & H58260061 Compliance Requirement: Procurement Award Period: 2025 Type of Finding: Material Weakness in Internal Control Over Compliance; Other Matters Criteria or specific requirement: The County must follow Uniform Guidance Subsection 200.320 Methods of Procurement for all applicable procurements over the County’s micro-purchase threshold. For purchases over the County's micro-purchase threshold of $10,000 but not exceeding the simplified acquisition threshold of $250,000, the County should follow small purchase procedures. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the County. Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There was no support showing open competition, cost analysis, or review and approval of selection tested. Questioned costs: None Context: One out of one selection tested had the above noted issues. Cause: The department did not follow the department's procurement policies during the year. Effect: The contracts selected did not go through open competition, cost analysis, or review and approval for the selection tested. Repeat finding: Yes – 2024-004. Recommendation: We recommend the County follow their federal purchasing policy in all their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are specific to each program to ensure this properly occurs. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2505MN5ADM - 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55245048 Compliance Requirement: Special Provisions Award Period: 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County and the Minnesota Department of Human Services (DHS) have a contract surrounding the federal funds. This contract has several obligations and reporting requirements the County must follow including the requirement the county must work with its collaborative partners to ensure that the LCTS coordinators and staff sampled by the LCTS have completed training approved by the State in the LCTS. Condition: The County was unable to provide a documented formal review process to ensure that LCTS fiscal site contacts were trained on completing cost schedules. Questioned costs: None Context: The County did not provide the documentation of the review over the noted requirement. Cause: The County did not maintain a record of their review process. Also, there has been fewer resources provided in recent years from the Minnesota Department of Human Services to help meet the specific training requirements of LCTS fiscal site contacts completing cost schedule reports. Effect: There is no way to verify the review process was completed and completed timely. Repeat finding: 2024-003 Recommendation: We recommend that the County reviews its polices and controls to ensure there is a formally documented control that ensures all required training of LCTS fiscal site contacts is completed and the documentation of the completions of the training is retained. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance & Supplemental Nutrition Assistance Program Cluster Assistance Listing Numbers: 93.778 & 10.561 Federal Award Identification Numbers and Years: 2505MN5ADM – 2025 & 232MN101S2514 – 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55250010 & H58260061 & H55255048 Compliance Requirement: Allowable Activities & Special Provisions Award Period: 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Minnesota Department of Human Services (DHS) requires a listing of employees working on social services programs to be submitted quarterly, known as a random moment study listing (RMS listing). DHS then determines the amount applicable to the applicable income maintenance programs through random moment studies. Each quarter the County’s coordinator reviews their RMS listing to ensure the employees listed are accurate for the people working and being coded in the general ledger. Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: One individual was included in the 1st and 2nd quarters of the Income Maintenance RMS listings sent to the State that was not supposed to be included in the listing. Questioned costs: None Context: Noted errors in two out of four quarterly RMS listings. One individual who was terminated at the end of 2024 was improperly included in the 1st and 2nd quarter RMS listings. Cause: The County's RMS controls and procedures were not robust enough to note that the RMS listings should have excluded the noted individual. Increased turnover and growth of the programs also created an increase in the number changes that were needed to be made to the listings. Effect: Lack of proper controls could affect allocation of fundings due to the staff not being properly listed on the income maintenance RMS listings. Repeat Finding: Yes 2024-002 Recommendation: We recommend that the County review its procedures and control to ensure all RMS listings sent to the State properly exclude those necessary individuals no longer working in the programs. Views of responsible officials: There is no disagreement with the audit finding.

Finding Number: 2025-003 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2025 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Significant Deficiency and Noncompliance – Matching Criteria: The Airport Improvement Program grant agreement requires the recipient to provide the required non-federal matching share for eligible project costs in accordance with the approved grant agreement and applicable federal requirements. Under 2 CFR 200.306, non-federal entities must meet applicable cost sharing or matching requirements. Matching contributions must be verifiable from the recipient’s records, not included as contributions for any other federal award, necessary and reasonable for the accomplishment of project objectives, allowable under the cost principles, and provided for in the approved budget when required. Additionally, 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During testing, we noted the Airport did not properly ensure that the required local matching contribution was provided and documented in accordance with the grant agreement. Specifically, the grant agreement required a non-federal/local match of five percent. However, the Airport’s accounting records and supporting documentation reflected a local match of ten percent, resulting in a match overstatement of $18,244 in 2025. The Airport did not have a formal review process in place to verify compliance with the required matching percentage before reimbursement requests were submitted. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Cause and Effect: The Airport did not have adequate internal controls to ensure that the required local match was calculated, tracked, reviewed, and documented throughout the grant period. Management relied on project expenditure records and reimbursement activity; however, it did not reconcile total eligible project costs to the required federal and non-federal cost-share percentages. Additionally, responsibilities for monitoring the matching requirement were not clearly assigned, and there was no documented supervisory review of match calculations. As a result, the Airport was not in compliance with the matching requirements of the Airport Improvement Program grant agreement. The federal match was understated, therefore no questioned costs identified. Recommendation: The Airport should establish and implement internal controls over federal grant matching requirements. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.

Finding Number: 2025-004 Federal Program: Airport Improvement Program Federal Award Identification Number and Year: All Airport Improvement Program awards, 2024, 2023 Assistance Listing Number (ALN): 20.106 Federal Awarding Agency: U.S. Department of Transportation Pass-through Entity: None Repeat Finding: No Material Weakness and Noncompliance – Allowability Criteria: Under 2 CFR 200.403, costs charged to federal awards must be allowable, meaning they are necessary, reasonable, allocable, adequately documented, and comply with the terms and conditions of the federal award. Additionally, 2 CFR 200.302(b)(7) requires financial management systems to include effective internal controls over accountability of expenditures, including proper review and approval. Per 2 CFR 200.303, the Entity must establish and maintain effective internal control over federal awards to provide reasonable assurance that expenditures are allowable and in compliance. Condition: During testing of expenditures charged to the Airport Improvement Program, we identified that the Airport did not consistently follow its established invoice approval procedures. Specially, two of five checks tested, invoices totaling $1,469,973, lacked documented evidence of CEO and Vice President of Landside, Planning & Infrastructure’s approval prior to payment. The invoices were approved for payment by the Vice President of Finance and Administration. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Cause and Effect: The CEO and Vice President of Landside, Planning & Infrastructure did not sign off on invoices for Airport Improvement Program expenditures as an indication of their approval and allowability. There is an increased risk of expenditures not being allowable if the control process is not properly followed. Recommendation: The Airport should ensure that all purchasing controls are followed when incurring expenditures of federal funds and that purchases are properly approved prior to payment. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.

Finding 2025-001 – Allowable Cost Principles – Payroll Evidence of Review (Significant Deficiency in Internal Control over Compliance) Criteria – In accordance with the Uniform Guidance 2 CFR 200.303 regarding internal controls, the Agency must establish and maintain effective internal control over the federal award that provides reasonable assurance that the Agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, per 2 CFR 200.430(i) “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed… These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.” Condition/context – Out of the total population of payroll transactions charged to this program, we selected a sample of forty (40) transactions using a random sampling methodology and noted three (3) instances where employee timecards did not have evidence of review or approval by the appropriate director or supervisor of the program in the system. We understand that the payroll process is designed to move forward even if approval is not documented in the system. Effect – Without proper internal controls over timecards, there is an increased likelihood that payroll costs charged to the federal program are incorrect. While timecard review/approval was not documented for 3 samples, based on testing performed, the related payroll was allowable per the grant. Cause – There appears to be inadequate internal controls and/or documentation of controls over review and approval of timecards, to ensure time is accurately reported and ultimately payroll costs are properly charged to the program. Repeat finding – This is not a repeat finding. Recommendation – The Agency should reexamine its processes and controls over payroll. This may also include providing additional training on the importance and relevance of accurate timecards and their impact with compliance requirements. Views of responsible officials – The responsible officials acknowledge the finding, concur with the recommendation and are actively working with the Human Resource Department to implement the program identified within the associated corrective action plan.

FINDING 2025-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Internal Controls Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SLFRP2104 Pass-Through Entity: Allen County Compliance Requirement: Reporting Audit Finding: Significant Deficiency INDIANA STATE BOARD OF ACCOUNTS 13 MAYSVILLE REGIONAL WATER AND SEWER DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The District was the recipient of a federal program subaward from Allen County, Indiana. Recipients of the subaward are required to submit a Monthly Project Spending Report (MPSR) for each month throughout the life of the grant to Allen County's grant administrator. Information to be reported on the MPSR includes original project funding, funds spent during the month, funds spent to date, planned percentage of project completion as of the end of the reporting month, and actual percentage of project completion. The Office Manager completed and submitted the MPSRs during the audit period as required; however, the District did not design and implement a review process or oversight for the reports prior to submission. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed or implemented by management of the District to ensure that MPSRs were prepared by one individual and reviewed by another individual before submission to Allen County's grant administrator. Effect Without the proper implementation of an effectively designed system of internal controls, errors could occur and remain undetected. As such, the District could not ensure that the reports submitted were materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the District establish a system of internal controls and develop policies and procedures over the preparation and review of monthly reports to ensure appropriate reviews, approval, and oversight are taking place. Additionally, management should develop policies and procedures to ensure that the District provides Allen County with complete and accurate information for all reports. INDIANA STATE BOARD OF ACCOUNTS 14 MAYSVILLE REGIONAL WATER AND SEWER DISTRICT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 15

Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.267 Program: Continuum of Care Program Award/Pass-Through Entity Identifying Numbers: DA-202407-02980, DA-202407-02967, 00002098 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 24 CFR §578.49(b)(1), “Where grants are used to pay for rent for all or a part of a structure or structures, the rent paid must be reasonable in relation to rents being charged in the area for comparable space. In addition, the rent may not exceed rents currently being charged by the same owner for comparable unassisted space.” Per 24 CFR §578.49(b)(2) and §578.51(g), “When grants are used to pay rent for individual housing units, the rent paid must be reasonable in relation to rents being charged for comparable units, taking into account the location, size, type, quality, amenities, facilities, and management services. In addition, the rents may not exceed rents currently being charged for comparable units, and the rent paid may not exceed HUD-determined fair market rents.” “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or subrecipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for comparable unassisted units, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: For 1 out of 13 clients tested, a comparable unit analysis was not formally reviewed and approved. For 6 out of 13 clients tested, the comparable unit analysis was not reviewed and approved until significantly after the preparation of the form. For 5 out of 13 clients tested, comparable unit analysis was completed after tenant move-in, of which 2 were completed more than 20 days after move-in. Cause: LifeWire’s supervisory staff did not timely review the rent reasonableness documentation. An emphasis on completion of the forms was included in procedures, however management is continuing to enhance procedures related to the timing of preparation and completion in advance of client move-in. Effect or Potential Effect: Lack of timely review of the comparable unit analysis could result in charging of unallowed expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of LifeWire’s compliance with specified requirements not using a statistically valid sample. Total costs subject to rent reasonableness were $947,816. Identification as a Repeat Finding: 2024-001. Recommendation: We recommend that LifeWire enforces the modified procedures to review approve, and retain rental reasonableness documentation, including the comparable unit analysis. Views of Responsible Officials: Management agrees with the finding that documentation was not timely reviewed. Management has modified its policies and procedures to ensure completion and review of rent reasonableness forms in a timely manner.

FINDING 2025-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2025 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 13 CITY OF CROWN POINT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002. Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) awards funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expended to equal or exceed $25,000 and all subawards. The verification is to be done by checking the System for Award Management (SAM) Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person or entity. A population of three covered transactions paid from the SLFRF award funds were identified and tested. None of the three covered transactions, totaling $2,436,774, did not include appropriate provisions in the contract, nor did the City require a certification, or check the SAM EPLS to ensure the entity was not suspended or debarred prior to making payment. The lack of internal controls and noncompliance was a systemic issue throughout the audit period and enabled material noncompliance to occur and remain undetected. Criteria 2 CFR 200.303 states in part: "The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control-Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states in part: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person . . . (c) Adding a clause or condition to the covered transaction with that person." INDIANA STATE BOARD OF ACCOUNTS 14 CITY OF CROWN POINT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management of the City did not have a formalized suspension and debarment policy to ensure procedures related to suspension and debarment requirements were in place and followed. Effect Any program funds the City used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the City develop written policies and procedures to ensure its compliance with requirements related to suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-002 Subject: Drinking Water State Revolving Fund - Suspension and Debarment Federal Agency: Environmental Protection Agency Federal Program: Drinking Water State Revolving Fund Assistance Listings Number: 66.468 Federal Award Number and Year (or Other Identifying Number): DW24414504 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context Prior to entering into subawards and covered transactions with the Drinking Water State Revolving Fund (DWSRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expended to equal or exceed $25,000 and all subawards. The verification is to be done by checking the System for Award Management (SAM) Excluded Parties List System (EPLS), collecting a certification from the person or entity, or adding a clause or condition to the covered transaction with that person or entity. A population of five covered transactions totaling $2,178,348 paid from the DWSRF award funds were identified and tested. Two of the five covered transactions totaling $85,000 did not include appropriate provisions in the contract, nor did the City require a certification, or check the SAM EPLS to ensure the entity was not suspended or debarred prior to making payment. The lack of internal controls and noncompliance were isolated to the two covered transactions. INDIANA STATE BOARD OF ACCOUNTS 15 CITY OF CROWN POINT SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control-Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the 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." Cause Management of the City did not have a formalized suspension and debarment policy to ensure procedures related to suspension and debarment were in place and followed. Effect Any program funds the City used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the management of the City develop written policies and procedures to ensure its compliance with requirements related to suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Subrecipient Monitoring and Special Tests: Housing Quality Standards Federal Department – U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: M17-DC170213 and 2017 M18-DC170213 and 2018 M21-DC170213 and 2021 M22-DC170213 and 2022 Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department – Department of Planning and Development (DPD) Finding 2025 – 001 CRITERIA Subrecipient Monitoring 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, “the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Section 200.332. Requirements for pass-through entities, requires that “A pass-through entity must: (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency)... (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must:(1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521.(4) Resolve audit findings specifically related to the subaward…. (g)Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. DPD’s HOME Program Policies and Procedures Manual (updated January 2025), Monitoring Section (pages 114 to 129), under the Annual Monitoring Plan/Schedule Update, states the plan should identify the participating jurisdiction (PJ) monitoring goals and strategies, highlighting areas to which staff should pay special attention during the monitoring year. A specific schedule detailing annual, bi-annual, and tri-annual monitoring visits as required by HUD must be developed and maintained. To assure that adequate records are kept regarding each property and its compliance status, the monitor should establish a monitoring file for each property. The basic items in the file should include written agreement, written tenant selection criteria, property and unit inspections and results, etc. Also, HOME Program Compliance should conduct a risk assessment of its portfolio of the PJ’s HOME projects so that the highest risk projects can be identified and monitored first. In addition, HOME Program Compliance must conduct a desk review of all properties in the monitoring workload each year, as well as on-site reviews periodically, ranging from annually to every 3 years based on the number of units in property (i.e. 26 or more units require an annual review). Special Tests: Housing Quality Standards Per 24 CFR Section 92.209(i), Tenant-based rental assistance: Eligible costs and requirements, Housing Standards, states “The participating jurisdiction must require the housing occupied by a family receiving tenant-based rental assistance under this section to meet the participating jurisdiction's property standards under § 92.251. Initially and annually thereafter, the participating jurisdiction must determine the housing complies with its property standards and is decent, safe, sanitary, and in good repair in accordance with § 92.251(f). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the PJ must perform on-site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing one to four units, (b) every two years for projects containing five to 25 units, and (c) every year for projects containing 26 or more units. CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not provide sufficient evidence to document annual monitoring performed, as well as performed the required inspections to ensure property standards were met, as required by Federal regulations and its internal policies. CAUSE Based on discussions with management, the cause of the findings occurred as a result of post pandemic allocations to the County which included several housing related fundings and initiatives, including Emergency Rental Assistance I & II (ERA I& II), Homeless Sheltering, Homeless and Transitional Sheltering Physical Site Acquisition and Development, HOME ARPA (HUD Allocation), and HOME, CDBG CV development delays that challenged the Housing teams provision of services and compliance requirement. While HUD had extended post pandemic compliance moratoriums into fiscal year 2024, Housing team hiring, training and implementation of compliance activities were unable to activate fully in the subject fiscal year to meet compliance. Additionally, for subrecipient monitoring of the HOME program, costs paid to developers were misclassified as subrecipient expenditures. The HOME program does not have contracts with subrecipients. EFFECT Failure to adequately monitor the activities and performance of subrecipients (and developers) could result in Federal awards being used for unauthorized purposes and DPD’s inability to adequately perform required risk assessments. Failure to perform the required inspections to ensure property standards were met is a violation of Federal regulations. QUESTIONED COSTS None. CONTEXT Subrecipient Monitoring During the current audit period, we noted a total of thirty-seven (37) projects were included on the Program Year 2024 (Fiscal Year 2025) HOME monitoring rental portfolio schedule provided, which required annual monitoring per DPD’s internal policies. Of the 37 projects, we noted three projects had some monitoring conducted during the period, which included some review of tenant files (for income verification/eligibility) and limited physical inspections of HOME units. No additional documentation was provided to verify compliance with federal regulations and the HOME Program Policies and Procedures Manual which required annual monitoring of each project (property). In addition, we noted approximately $7.3 million was reported on the SEFA as pass-through to two subrecipients under the program for the fiscal year ended November 30, 2025. Based on further discussions, DPD noted that these subrecipients are the two title companies used to pay the developers under the HOME program in accordance with its escrow agreement(s). We also reviewed a sample of these payments noting the supporting documentation referenced the developers as subrecipients. No documentation was provided to support compliance with subrecipient monitoring as required by 2 CFR Part 200.332. Special Tests: Housing Quality Standards We were provided with the same 37 projects reviewed under subrecipient monitoring to verify that DPD performed the required inspections to ensure that property standards were met. Based on our review, we noted the list included projects with HOME assisted units ranging from one (1) to 99 units, which would have required inspections every one to three years. However, the listing provided did not identify those units on which housing quality inspections were due. In addition, of the 37 projects, we were provided with documentary evidence to support only one (1) project whereby the required unit inspection reports were completed. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPD ensure procedures should be in place to ensure adequate documentation is maintained to support the evaluation of each subrecipient’s risk of noncompliance, as required by Federal regulations and internal policies. Also, documentation should be maintained to support that required inspections are performed to ensure that property standards are met, including identification of those units on which housing quality inspections are due, in accordance with 24 CFR 92.251(f). VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on pages 42-43.

Information of the Federal Program: Assistance Listing Number 10.565—Commodity Supplemental Food Program, U.S. Department of Agriculture Pass-Through Entity and Award Number: Minnesota Department of Health, award number 204642. Compliance Requirement: Eligibility Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a recipient to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including eligibility. Condition: We requested eligibility forms for forty participants to review for the signature of site partner personnel indicating review of eligibility information on the form. One of the forty forms were unable to be located upon request. Eligibility information is input in ClientTrack software and the form should also be uploaded. Cause: Signed enrollment forms were not properly scanned into Sharepoint and had likely been disposed of. The signatures on these forms indicated the review by an agency partner that information included on the form is correct. Effect or Potential Effect: An ineligible individual could receive a CSFP box. Questioned Costs: None Context: Signed enrollment forms were not available for one of forty participants selected. Repeat Finding: yes, 2024-001 Recommendation: We recommend that Second Harvest Heartland digitalize their CSFP enrollment forms for convenient access and provide review of the electronically filed form prior to disposal of the paper form. Views of Responsible Officials: Agree.

Information on the Federal Program: Assistance Listing Number 10.565—Commodity Supplemental Food Program, U.S. Department of Agriculture Pass-Through Entities and Award Numbers: Minnesota Department of Health, award number 204642. Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs and Cost Principles Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a recipient to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Activities Allowed or Unallowed and Allowable Costs and Cost Principles. Condition: Processes and procedures in place to review and submit administrative expenditures did not include a thorough enough review process to agree information to source data. Cause: Expenditures were reviewed before submission, however the review of this information was inadequate as it did not corroborate totals with the source data. Effect or Potential Effect: The Organization could have received reimbursement in excess of incurred expenses. Questioned Costs: None Context: One of the months selected for detail testing was found to have an erroneous submission using the wrong month’s expenditures. However, because the Organization incurred significantly more expenses than for which it was reimbursed during the year, the erroneously reported expenses had not been reimbursed by the funder. Repeat Finding: No Recommendation: We recommend that Second Harvest Heartland review the source data for all future expense reports. Views of Responsible Officials: Agree.

Department of Health and Human Services Temporary Assistance for Needy Families, Passed through Ramsey County, Federal Financial Assistance Listing 93.558, FAST X award 2201MNTANF for the year ending 12/31/2024 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees’ pay to grants in a timely manner in accordance with their established policy, however, during the year for one pay period tested, an error was identified in the process but was not fully corrected. Cause: Goodwill-Easter Seals Minnesota has a process for allocating employee wages based on hours worked. The controls in place did not operate as designed and failed to fully correct an error in the allocation of employee pay to the grant. Effect: One employee had some of their pay allocated improperly and not in accordance with the policy established. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of eight pay periods out of 26 were selected for testing which accounted for $383,866 of $2,284,613 of federal program expenditures. Repeat Finding from Prior Year: Yes Recommendation: We recommend that management develop a more extensive review over payroll allocation to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.

Department of Health and Human Services Temporary Assistance for Needy Families, Passed through Ramsey County, Federal Financial Assistance Listing 93.558, MFIP award 2201MNTANF for the year ending 12/31/2025 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Goodwill-Easter Seals Minnesota’s internal control structure should be designed to properly follow the allocation policy for employees’ pay to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Condition: Goodwill-Easter Seals Minnesota has an internal control system designed to detect or prevent improper allocation of employees’ pay to grants in a timely manner in accordance with their established policy, however, during the year for five pay periods tested, Goodwill-Easter Seals Minnesota failed to identify that one employee’s timecard had incorrectly allocated time to a grant that ended. However, the time was corrected before submission to the grant, but it was not changed on the timecard. Cause: Goodwill-Easter Seals Minnesota has a process for approving timecards which include program codes for allocation to awards. The controls in place did not operate as designed and failed to fully correct an error in five timecards of an employee’s pay to the grant. Effect: One employee had the incorrect program code listed on the approved timecard for five pay periods tested. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of eight pay periods out of 26 were selected for testing which accounted for $383,866 of $2,284,613 of federal program expenditures. Repeat Finding from Prior Year: Yes Recommendation: We recommend that management develop a more extensive review over timecards to ensure pay is properly allocated to each grant in accordance with the policy established by Goodwill-Easter Seals Minnesota. Views of Responsible Officials: Management agrees with this finding.

Item 2025-001 Eligibility/Program Eligibility Federal Pell Grant Program ALN# 84.063 U.S. Department of Education Grant period – 2025-2026 Award Year Criteria – In accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should follow 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). Under 34 CFR Part 690 Pell grants are required to be calculated using a distinct set of criteria based on enrollment. Condition – 2 of 40 students tested received overpayments of Pell grants. Errors in clock-to-credit-hour conversions resulted in inaccurate enrollment intensities used in the Pell calculations for these students. Cause – The data file for the clock-to-credit hour conversion was not uploaded into the College's system prior to calculation of the students' enrollment intensity, and the results were not reviewed prior to packaging aid. Effect – Lack of controls resulted in an overpayment of Pell award to both students. The engagement team notes that for these exceptions, the College appropriately updated the file and corrected student aid. The engagement team further notes this only affected students in a current enrollment period in which all funds for the term had not been drawn from the Department of Education. Questioned Costs – The total of all overpayments was $7,821 amount was deemed not material to compliance. Recommendation – We recommend that adequate controls be put in place to review that files are updated by semester and that clock-to-credit hour conversions are reviewed prior to awarding of federal aid. Management’s Response – The College will strengthen the controls in place to ensure that all procedures have been followed prior to calculation and disbursement of financial aid.

Federal Agency: Department of Health and Human Services Federal Program Name: Special Programs for the Aging-Title III, Part C-Nutrition Services Assistance Listing Number: 93.045 Federal Award Identification Number and Year: 316-24-00C1-042, 316-24-00C2-043, 316-25-00C1-042, 316-25-00C2-043 and 316-25-00C3-042 Pass-Through Agency: MN River Agency on Aging Pass-Through Number(s): 316-24-00C1-042, 316-24-00C2-043, 316-25-00C1-042, 316-25-00C2-043 and 316-25-00C3-042 Award Period: January 1, 2024 – December 31, 2024 & January 1, 2025 – December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: 2 CFR 200.306 requires that any amounts used for required cost sharing must be verifiable in the subrecipient’s records and allowable under subpart E. 2 CFR 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our audit testing, we observed discrepancies between the hours reported by volunteers and the hours submitted for the grant at two sites. There were also 3 volunteer logs that could not be located related to two sites. Additionally, there was not documentation of the signoff on the volunteer logs by the site coordinator for two sites. Context: We reviewed 40 volunteer logs for reported hours. Differences in the hours reported were between 0.25 and 0.75 hours. Cause: In 2024, funding cuts led to temporary disruptions, resulting in staff reductions and affecting documentation practices in a particular timeframe. Regarding the hours reported that did not align with the volunteer log, the site coordinator believed the volunteer had underreported their hours and adjusted them accordingly, but there was not documentation of the change. Additionally, there was one instance where a data entry error contributed to the discrepancies. Effect: Hours reported for volunteer time could be incorrect. This grant requires a cost share of 15% be provided and the required cost share of 15% was exceeded so there was not an effect of meeting the required cost share. Repeat Finding: No Recommendation: We recommend additional training to ensure documentation is kept for the volunteer logs and the review. We also recommend documentation for any discrepancies between hours reported vs. the volunteer log. Views of responsible officials: There is no disagreement with the audit finding.

Assistance Listing Number, Federal Agency, and Program Name ALN 20.106, U.S. Department of Transportation Federal Aviation Administration (FAA), Airport Improvement Program (AIP) Federal Award Identification Number and Year 3 48 0064 161 2025 Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria The Code of Federal Regulations, specifically 2 CFR 200.303, requires grant recipients establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition The controls in place to review the final grant packet, including the grant drawdown template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Questioned Costs $21,452 If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported N/A Identification of How Questioned Costs Were Computed The questioned costs represent the total of all nonconforming costs reduced by the Airport's 25 percent match that were charged to the grant. Context Although the two invoice packets properly identified the $28,603 of non conforming costs out of $25,412,561 incurred, the grant drawdown template that was prepared did not exclude these ineligible costs and the review of the grant drawdown template did not identify the error prior to final processing of the drawdown. Cause and Effect The ineffective control to ensure accuracy of the grant drawdown template prior to final processing of the drawdown resulted in unallowable costs. Recommendation We recommend the Airport ensure internal controls are in place to ensure accurate information is included in the final processing of the drawdown. Views of Responsible Officials and Planned Corrective Actions Treasury will work with PMM and DCC departments to out line a process to ensure accurate reporting of eligible expenses when invoices are re viewed for compliance with grant program requirements. The process will be documented and adhered to once agreed by all departments. A review process for the final drawdown submission will also be adopted to ensure costs that are identified as ineligible are appropriately excluded from the final submission.

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

2025 001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Beneficiary Payments U.S. Department of State: Bureau of Population and Refugees and Migration: U.S. Refugee Admissions Program: FY24 MRA Capacity Development Funds (ALN 19.510, award number SPRMCO23CA0361) FY2023 25 Year 3 Reception and Placement Program Affiliate MRA DA+Admin (ALN 19.510, award number SPRMCO24CA0356) FY2023 25 Year 3 Reception and Placement Program Affiliate ERMA DA+Admin (ALN 19.510, award number SPRMCO24CA0357) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Significant Deficiency and noncompliance Criteria: 2 CFR section 200.303 requires that non federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non federal entity is managing the federal awards in compliance with federal statues, regulations, and the terms and conditions of federal awards. The specific requirements for activities allowed or unallowed are unique to each federal program and are found in the federal statutes, regulations, and the terms and conditions of the federal award pertaining to the program. 2 CFR Part 200 establishes cost principles for determining costs applicable to federal awards with nonprofit organizations. The Uniform Guidance (2 CFR 200.403) requires that costs charged to federal awards be necessary, reasonable, allocable, adequately documented, and in compliance with the terms and conditions of the federal award. Costs that do not provide a direct programmatic benefit, or where the benefit cannot be reasonably demonstrated or allocated, and are incurred outside the approved scope of the award are not allowable as direct charges. Condition and context: On February 13, 2025, IRC’s Ethics & Compliance Unit (ECU) received a whistleblower report alleging that an IRC Housing Coordinator located in an office in Northern California submitted unauthorized and fraudulent requests for funds, which were uploaded onto USIO bank debit cards, claiming they were expenses for newly resettled IRC clients, and instead using the funds for personal benefit. These USIO cards are intended to be used to cover expenses for newly arrived refugees during the initial 90 day period, including rent, food and other miscellaneous expenses. An internal investigation was initiated in February 2025 which found that the Housing Coordinator had loaded funds onto USIO bank debit cards between May 8, 2023 and February 11, 2025 which were for purposes other than refugees. The investigation concluded that there were unauthorized and fraudulent requests for funds in the amount of $215,639, plus the related indirect costs that were applied on these direct costs of $33,920, for a total of $249,559 related to federal funds expended in 2025 and charged to the grants identified in this finding. The total expenditures in this program included on the 2025 schedule of expenditures of federal awards amount to $42,671,438. This unauthorized and fraudulent requests for funds noted of $249,559 is not included in the total expenditures in this program on the 2025 schedule of expenditures of federal awards as the amounts were recoded to unrestricted funds. IRC communicated this matter to the federal agency in February 2025 when the investigation began and again in September 2025 when the investigation was completed. The expenditures were reallocated to IRC’s unrestricted funds so that the federal grants were not charged. Cause: The internal investigation completed by ECU concluded that the unauthorized and fraudulent requests for funds resulted from the Housing Coordinator’s ability to request the transactions and approve the transactions because he obtained his direct report’s general ledger log in credentials. Additionally, there were several control gaps in the Northern California office, including the following: • There was a lack of safekeeping of blank USIO Cards – this office was not following the established control to keep the blank cards in a locked safe. • USIO cards were not tracked or recorded properly – this office was not always following the established control to have the refugees sign a log book upon receipt of a USIO card. • A lack of oversight from the heads of programs and finance in this office regarding reconciliations between budgeted and actual amounts with irregular transactions being flagged (excessive housing expenses). Effect: The auditee charged certain costs directly to the program that did not meet the requirements noted above, and were therefore, not allowable. Questioned Costs: Questioned costs were $249,559, however, IRC reallocated these costs to IRC’s unrestricted funds, so that the grants were not charged. Recommendation: IRC should design and implement enhanced internal control procedures over the authorization and disbursement of funds to IRC refugee clients through USIO cards to ensure that funding provided is allowable. Additionally, IRC should provide training to employees about sharing their personal credentials to access IRC’s general ledger. Views of Responsible Officials: Management agrees with this finding, which was identified by IRC in February 2025 and raised to KPMG prior to the single audit. Corrective actions related to USIO portal access, office leadership and structure, training and policies, and spot checking have been implemented and will continue through June 2026.

2025 002 Reporting Federal Funding Accountability and Transparency Act U.S. Department of State: Bureau of Population and Refugees and Migration: Overseas Refugee Assistance Program for Middle East and North Africa: Provision of lifesaving protection & health response for Syrian refugees and vulnerable Lebanese (ALN 19.519, award number SPRMCO24CA0321) Overseas Refugee Assistance Program for South Asia: Comprehensive, Integrated Multi Sector Response for Rohingya Refugees and Host Communities in Cox’s Bazar (Y2) (ALN 19.523, award number SPRMCO24CA0239) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Improved (Re)integration Services Activity (ALN 98.001, award number 72052224CA00004) Lifesaving Integrated Humanitarian Services in Underserved Areas of Sudan (ALN 98.001, award number 720BHA22GR00218) Statistically valid sample: No, and it was not intended to be. Repeat finding: Yes (2024 001). Finding Type: Significant deficiency and noncompliance Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109 282), as amended by Section 6202 of Public Law 110 252, (Transparency Act) that are codified in 2 CFR Parts 25 and 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first tier subawards of $30,000 or more to System for Award Management (SAM.gov). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards and contractors (i.e., prime contractors) that award first tier subcontracts. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Condition and context: For ALN 19.519, there were 3 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 30, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission date for both agreements to be August 21, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions:7 Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $403,678 Subaward not reported: $0 Report not timely: $403,678 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 19.523, there were 4 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 2 of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for both agreements was not submitted timely. Both of the agreements were entered into on September 1, 2024 and had a submission due date of October 31, 2024. SAM.gov notes the submission dates to be December 4, 2025 and December 8, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 2 Subaward not reported: 0 Report not timely: 2 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $759,550 Subaward not reported: $0 Report not timely: $759,550 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2025 that required FFATA reporting. We selected 5 for test work and noted that while all the key data elements were accurately submitted, the information for 4 of these agreements was not submitted timely. Two of these agreements were entered into on November 1, 2024, one was entered into on November 22, 2024 and the last was entered into on December 1, 2024. The submission due dates for these agreements were December 31, 2024 and January 31, 2025. SAM.gov notes the submission dates for three of these agreements to be December 18, 2025, and for the one agreement entered into on November 22, 2024, the submission date was noted to be January 7, 2025. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested: 5 Subaward not reported: 0 Report not timely: 4 Subaward amount incorrect: 0 Subaward incorrect key elements: 0 Dollar amount of tested transactions: $302,280 Subaward not reported: $0 Report not timely: $291,135 Subaward amount incorrect: $0 Subaward incorrect key elements: $0 Cause: Following the federal system migration, the USG FFATA reporting platform within SAM.GOV no longer displayed or made readily retrievable the submission date associated with individual FFATA. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting and maintaining appropriate documentation to evidence timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized and documenting that review in writing. Additionally, we recommend that IRC take screen shots during the submission process and maintain these with the subawardee agreements. This will evidence the submission in SAM.gov, specifically evidencing the submission date. Views of Responsible Officials: While Management maintains it acted in good faith to ensure all FFATA submissions are provided timely, the new FFATA reporting platform issues made it difficult for IRC to substantiate the dates of submission. IRC did contact FSD.gov to confirm what form of evidence would be considered sufficient in the absence of visible system date stamps. FSD.gov was unable to provide specific confirmation and instead directed IRC to published guidance https://www.fsd.gov/gsafsd_sp/en/under the federal funding accountability and transparency act how acknowledging existing “implementation challenges”. This guidance shifts the focus of compliance validation from system generated timestamps to whether the recipient acted in good faith to comply with reporting obligations. Relying on this, IRC’s internal control framework did not include a secondary documentation mechanism to independently evidence submission dates in the event that system functionality limited visibility. However, IRC remains committed to full FFATA compliance and will incorporate additional steps to strengthen the compliance documentation trail.

REFERENCE: 2025-101 CFDA NUMBER: 10.558 – CHILD AND ADULT CARE FOOD PROGRAM U.S. DEPARTMENT OF AGRICULTURE - FOOD AND NUTRITION - 2025 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER 6AZ300003 QUESTIONED COSTS N/A CONDITION The following errors were noted during testing of FDCH Site Claims and 18 Day Care Home provider files for the months of May 2025 and September 2025: 1. For 1 of 18 provider files tested, menus were clerically inaccurate and did not support the meals claimed in September 2025. 2. For 1 of 18 provider files tested, meals were claimed for the incorrect meal type. Afternoon Snacks were claimed rather than Evening Snacks. This error occurred during September 2025. 3. For 1 of 18 provider files tested, meals were incorrectly disallowed when a credible meal component was provided. This error occurred in May 2025. 4. For 1 of 18 provider files tested, meals were claimed when a child was not in attendance. This error occurred in May 2025. 5. For 2 of 18 provider files tested, although 3 monitoring visits were completed, documentation was not available to demonstrate that 2 of the visits were unannounced. 6. For 2 of 18 provider files tested, the five-day reconciliation on a sponsor monitoring visit was not completed. For 1 provider's visit the reconciliation was only completed for 4 days, and for the other provider there was no indication of the number of children signed in for any of the 5 days tested. These errors resulted in the following revised meal counts: These variances resulted in an under payment (known questioned costs) of $100. However, after projecting the various types of errors over six meal categories for the entire year, likely under reported costs totaled $5,531. CRITERIA In accordance with the Arizona Department of Education, Day Care Home Compliance Manual, Revised June 2019, Chapter 10, Meal Requirements, Section 10.7 Other Meal Requirements, in order to claim a meal, the provider must abide by the following criteria: • The provider must serve a fully reimbursable meal that meets the meal pattern requirements and are supported by complete and up to date attendance, meal count, and menu records; • The child must be present and participate in the meal service; • All meal components must be served together; • The meal must be fully consumed on the premises in a congregate setting. Meals sent home with a child due to the parent picking up the child during meal service cannot be claimed; • Meal must be served during approved meal service time; • The provider can be reimbursed for a maximum of two meals and one snack or two snacks and one meal per child, per day; • Only children who are enrolled can be claimed and the number of children cannot exceed the allowable ratio; • Payment may be made for meals served to provider’s own child(ren) or foster children only when:  Their child(ren) are enrolled and participating in the child care program during the time of the meal service;  At least one enrolled, non-resident child is present and participating in the child care program;  The provider meets the family size income standards for free or reduced price meals; • Seconds may be served but are not reimbursable; and • If a school age child receives a breakfast, lunch or afterschool snack at school, a provider may not claim the same meal. In accordance with 7 CFR, Subtitle B, Chapter II, Subchapter A, Part 226, Subpart E Operational Provisions, §226.16 (d)(4)(ii) Reconciliation of meal counts. Reviews must examine the meal counts recorded by the facility for five consecutive days during the current and/or prior claiming period. For each day examined, reviewers must use enrollment and attendance records (except in those outside-school-hours care centers, at-risk afterschool care centers, and emergency shelters where enrollment records are not required) to determine the number of participants in care during each meal service and attempt to reconcile those numbers to the numbers of breakfasts, lunches, suppers, and/or snacks recorded in the facility's meal count for that day. Based on that comparison, reviewers must determine whether the meal counts were accurate. If there is a discrepancy between the number of participants enrolled or in attendance on the day of review and prior meal counting patterns, the reviewer must attempt to reconcile the difference and determine whether the establishment of an overclaim is necessary. In accordance with 7 CFR, Subtitle B, Chapter II, Subchapter A, Part 226, Subpart E Operational Provisions, §226.16 (d)(4)(iii), Frequency and type of required facility reviews. Sponsoring organizations must review each facility three times each year, except as described in paragraph (d)(4)(iv) of this section. In addition: (A) At least two of the three reviews must be unannounced; (B) At least one unannounced review must include observation of a meal service; (C) At least one review must be made during each new facility's first four weeks of Program operations; (D) Not more than six months may elapse between reviews; (E) The timing of unannounced reviews must be varied so that they are unpredictable to the facility; and (F) All types of meal service must be subject to review and sponsoring organizations must vary the meal service reviewed. In accordance with the Uniform Guidance, Compliance Supplement, Part 6 – Internal Control, 2 CFR section 200.303 requires that recipients and subrecipients receiving federal awards establish, document and maintain effective internal control over the federal awards that provides reasonable assurance that the recipient or subrecipient is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. EFFECT Program requirements were not complied with. Additionally, meal reimbursements were clerically inaccurate and the providers were incorrectly reimbursed. CAUSE Although the internal controls were adequately designed, there were deficiencies in the execution of the controls. Most menu errors occurred on paper menus, which have a higher risk of errors. RECOMMENDATION AND BENEFIT Menus should be reviewed to ensure all eligible meals are claimed, and provider meal count sheets should be reviewed for clerical accuracy and completion prior to the preparation of the reimbursement claim. Additionally, monitoring visits should be reviewed to ensure that all required information is properly included, including completion f the five day reconciliations and indication if the review is unannounced and . These reviews should be documented. This will help ensure that program requirements are complied with and only eligible meals served to eligible participants are claimed for reimbursement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

2025-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement (Significant Deficiency) Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Direct Award Numbers Award Period 720BHA23GR00031 February 1, 2023 through January 31, 2026 72068324GR00002 September 7, 2024 through December 31, 2024 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Subaward Reporting in SAM.gov. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: We performed testing over CRS’s compliance with specific FFATA reporting requirements. Of the eight sub-award reports selected for testing, two of the reports with sub-award amounts totaling $313,190 were not submitted within the required timeframe. Specifically, the two FFATA reports were filed between 64 and 66 days later than the required filing date. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The samples were selected using a non-statistical sampling method. Cause: Although CRS has existing internal control policies and procedures ensuring appropriate filing of sub-award information in SAM.gov, the country offices failed to file the FFATA reports on time. Effect: Failure to report subrecipient information in a timely manner can result in lack of transparency and accountability, which is contrary to the intent of FFATA. Such non-compliance also increases the risk of loss of future awards if compliance with award terms is not met. Repeat Finding: No. Recommendation: We recommend that management ensure that all FFATA reports are filed in a timely manner. In addition, management should strengthen the existing internal controls and conduct refresher training to CRS country office personnel emphasizing timely submission of FFATA reports. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the processes around timely submission of FFATA reports.

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Head Start Federal Assistance Listing Number: 93.600 Award Period: June 1, 2024 to June 30, 2025, August 1, 2024 to July 31, 2025, July 1, 2025 to May 31, 2026, August 1, 2025 to July 31, 2026 Type of Finding:  Significant Deficiency in Internal Control over Major Federal Programs and Other Matters Criteria or Specific Requirement: The organization must train all governing body and policy council members within 180 days of the beginning of the term of a new governing body or council. Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing we noted one new board member did not have support verifying they received the appropriate training. This individual was a past employee who would have received the training while employed but no support was retained to support that the training was done. Questioned Costs: N/A Context: No documentation was retained to support that a new board member had proper training. Cause: Individual was a past employee who would have received the training while employed but not support was retained to support that the training was done. Effect: Potential for a board member to not have the proper knowledge and understanding of how to provide adequate oversight of the Head Start program. Repeat Finding: No Recommendation: Ensure support is retained to show all new board members received training within 180 days. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

Finding 2025-009 – Reporting (Material Weakness and Noncompliance)(Repeat Finding) Identification of the Federal Program: Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG) and Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.328-330 establish the requirements of nonfederal entities for financial and performance reporting that include timely and accurate reporting. 2 CFR 200.303 requires nonfederal entities to establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Typical control procedures for reporting include having a supervisor review the submitted report and ensuring the work is performed and documented in a way that confirms the accuracy and completeness of all data and information included. Condition: We selected five reports for the two grant programs to test for compliance and controls over reporting requirements. No documentation of review or approval of the reports was available. For CDBG, 2 quarterly cash reports and the FY24 Consolidated Annual Performance and Evaluation Report (CAPER) were tested, one cash report was late. Cause: The City did not retain documentation of a review and approval of federal reports submitted. Effect: The City did not have appropriate controls in place over documentation of reporting requirements. Questioned Costs: None reported. Recommendation: We recommend the City strengthen its policies and procedures over the grant reporting process to ensure controls are properly implemented and working effectively. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.

ESTABLISH, DOCUMENT, AND MAINTAIN EFFECTIVE INTERNAL CONTROL OVER THE FEDERAL AWARD THAT PROVIDES REASONABLE ASSURANCE THAT THE RECIPIENT OR SUBRECIPIENT IS MANAGING THE FEDERAL AWARD IN COMPLIANCE WITH FEDERAL STATUTES, REGULATIONS, AND THE TERMS AND CONDITIONS OF THE FEDERAL AWARD. THESE INTERNAL CONTROLS SHOULD ALIGN WITH THE GUIDANCE IN “STANDARDS FOR INTERNAL CONTROL IN THE FEDERAL GOVERNMENT” ISSUED BY THE COMPTROLLER GENERAL OF THE UNITED STATES OR THE “INTERNAL CONTROL-INTEGRATED FRAMEWORK” ISSUED BY THE COMMITTEE OF SPONSORING ORGANIZATIONS OF THE TREADWAY COMMISSION (COSO), 2 CFR 200.303.

Condition: During our testing of controls over payroll, we identified three instances of payroll summary reports lacking an indication of review and approval. Criteria: The Uniform Guidance 2 CFR 200.303 requires auditees to establish and maintain effective internal control over federal awards that provides reasonable assurance that the awards are being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Organization should have a system of internal control in place to provide reasonable assurance that payroll summary reports are accurate and are being reviewed. Cause: The Organization has experienced significant turnover in HR positions and has had the Executive Director and Finance Manager take on these duties, along with their normal duties, until a replacement can be found. Effect: In the absence of review, payroll errors may go undetected, potentially resulting in inaccurate payroll records and payments. The possibility of fraud or noncompliance occurring and not being prevented or detected and corrected is present. Context: During our testing of a sample of six payroll summary reports, we noted an instance of a lack of review and approval. We then expanded the sample to 12 payroll summary reports, identifying one further instance of lack of review and approval, at which point the sample was again expanded to 24. A third instance was identified during the testing over the expanded sample, at which point testing ceased, and we determined that we could not rely on controls. The control deficiency did not result in a material impact on the program and did not reach the threshold for reporting questioned costs. Repeat of Prior Year Finding: No Auditor’s Recommendation: We recommend that payroll summary reports be reviewed and approved prior to completing the payroll process. If the Executive Director is unavailable, another staff member should review and approve the reports so the payroll process can be completed. View of Management: Management agrees with the finding. A response can be found in the Corrective Action Plan.

2025-001 – Internal Control over Compliance and Compliance with Reporting Information on the Major Federal Program: Federal Agency: Department of Interior Program Name: National Park Service Second Century Endowment and Appropriation Assistance Listing Number: 15.U01 Award Number: H.R. 4680/P.L. 114-289 Award Period: October 1, 2024 to September 30, 2025 Criteria – The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the requirements 2 CFR §1402.300(b), a non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of the Federal Funding and Accountability Act (FFATA), which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170, Reporting Subaward and Executive Compensation Information. In accordance with 2 CFR Part 170, Appendix A, under FFATA, the Foundation is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition – During our testing of reporting, we selected five subrecipient awards. For all samples tested, the Foundation did not comply with the mandatory FFATA report filing requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 5 5 5 Not applicable – no report was submitted Not applicable – no report was submitted Dollar Amount of Tested 2025 Subawards Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 319,000 $ 319,000 $ 319,000 Not applicable – no report was submitted Not applicable – no report was submitted Cause - The Foundation did not have adequate policies and procedures in place to ensure compliance with the FFATA filing requirements. Effect or Potential Effect - Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance and awarding agency taking administrative action. Questioned Costs – None. Context - This is a condition identified based upon our review of the Foundation’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these finding is detailed in the condition section above. Repeat Finding – This is a repeat finding from prior year. This was reported as finding 2024-001 in the 2024 report. Recommendation – BDO noted management’s actions to continuously work with federal grantor/agencies to address the prior year finding. However, the Foundation’s grant agreement does not have a Federal Award Identification Number (FAIN) which is a requirement to comply with FFATA reporting, therefore management is still unable to file the required FFATA reporting. BDO recommends that the Foundation continue to work with federal grantor/agencies to determine the required information and immediately comply with the FFATA requirements. Views of Responsible Officials – The Foundation’s management has been given a legal opinion from counsel that the Appropriation and the Endowment are exempt from the Uniform Guidance and the Single Audit. As such, will continue to work with Department of Interior to remedy this situation. The planned corrective actions are presented in the Foundation’s management’s corrective action plan attached as Appendix C.

Department of Housing and Urban Development - Direct Project - Community Development Block Grant- ALN 14.218- Program Year 2025 (B-20-UC-11-0018 FY 2021, B-20-UW-12-0018 FY 2020, B-22-UC-12-0018 FY 2022, B23-UC-12-0018 FY 2023, B-24-UC-12-0018 FY 2024, FR-6512-N-01 FY 2024) Criteria — 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the non‐federal entity must: (a) Establish and maintain effective internal controls over Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition — There was no evidence of the controls in place to review and approve reports prior to submission. The lack of internal control is a systemic issue over reporting. Cause/Effect—There is no evidence of the internal control requiring review and approval prior to submission of the cash on hand quarterly report and the FFATA reports prior to submission. If the internal controls are not in place the reports might not be accurately and timely filed, which could cause a delay in payment or loss of funding. Questioned Costs– None noted. Reported finding is for noncompliance in the reporting compliance requirement that does not affect the amount expended or received from the Federal award. Auditor’s Recommendation – Develop an internal control process with evidence of a review of reports prior to submission. CRI also recommends that the County develop a process to track all grant reports required by ALN#/CSFA# and by contract. This system would provide a repository of all the required reporting which the county could use to verify reports are filed timely and accurately. Management Response – See Corrective Action Plan Letter.

Interest Earned on Federal Funds. Criteria: 2 CFR 200.303 provides that non-federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with Uniform Guidance. 2 CFR Section 200.305 sets forth the requirements for the return of interest earned on federal funds. Recipients of federal grants are required to establish internal controls to minimize the time that elapses between the receipt of federal funds from the grantor, and the payment of those funds to vendors who provide goods or services. Interest earnings that exceed $500 per year from excess cash balances must be paid to the federal grantor. Condition: CASIS did not calculate interest earnings on the federal cash balance to determine if any earnings should be repaid to the grantor. Cause: CASIS does not have a policy to monitor federal cash balances for cash management requirements, including the calculation of interest earnings. Effect: CASIS did not take steps to reduce the time elapsing from the date it received federal funds to the date it spent the funds on program costs. The lapse resulted in interest earned on federal funds. Questioned Costs: Fontana calculated that CASIS earned approximately $17,000 of interest on the federal funds balance for the fiscal year ended September 30, 2025. Interest earnings on federal funds of more than $500 must be returned to the grantor. Perspective: Interest was not calculated or returned to the grantor for fiscal year ended September 30, 2025. Recommendation: Fontana recommends that CASIS: o Implement controls to minimize the time between receipt of funds from the granting agency and disbursement of those funds. o Compute interest earned on advance funds and remit amounts in excess of $500 to the grantor when required.

Finding 2025-001: Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Federal Awarding Agency: U.S. Department of Housing and Urban Development (HUD) Department: Department of Housing and Community Development (DHCD) Program name: Housing Voucher Cluster ALN: 14.879 Compliance Requirement: Special Test-Housing Quality Standards (HQS) Inspection and Enforcement Prior Year Finding Number: N/A Criteria or Specific Requirements: Per 24 CFR 982.404 “The public housing Organization (PHA) must not make any housing assistance payments (HAP) for a dwelling unit that fails to meet the HQS, unless the owner corrects the defect within the period specified by the PHA and the PHA verifies the correction. If a defect is life threatening, the owner must correct the defect within no more than 24 hours. For other defects, the owner must correct the defect within no more than 30 calendar days (or any PHA-approved extension)”. Additionally, per 24 CFR 982.405 “The PHA must inspect the unit at least biennially during assisted occupancy to ensure that the unit continues to meet the HQS”. Per 2 CFR section 200.303, non-Federal entities receiving Federal awards must establish and maintain internal control designed to ensure reasonably compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Condition: During our testing of sixty (60) inspections, we noted the following: - One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to abate the housing assist payments (HAP) or terminate the HAP contract for this unit in a timely manner. Additionally, for this unit the inspection was not performed on the required biennial basis. Questioned Costs: We identified $984 in known and $54,962 in likely questioned costs as a result of our sampling and testing procedures. Cause: The Organization did not follow the internal controls, policies and procedures in place to ensure inspections and re-inspections of units are performed on a timely basis. Context: This is a condition based on testing of the Organization’s compliance with specified requirements. The prevalence of the finding is detailed in the Condition section above. The samples were selected using a nonstatistical method. Effect: The Organization’s control environment over HQS enforcements did not ensure that re-inspections were performed timely or documented within the system or that HAP abatements occurred in a timely manner. As a result, the Organization was not in compliance with the HQS enforcement requirements as of September 30, 2025. Non-compliance with these requirements creates a risk that the Organization may provide federal funds to tenants of ineligible units. Recommendation: We recommend the Organization review their system functionality to determine whether an electronic process for scheduling and follow-up or comprehensive reporting can be identified to improve efficiency and eliminate the potential for human error. If an electronic process or comprehensive reporting is not available, or cannot fully cover the deficiency, we recommend the Organization look into measures to streamline their current internal controls, policies and procedures to eliminate non-compliance. Potential examples include adding an inspection checklist, having the inspection supervisor review and schedule upcoming inspections in advance, building room into the schedule for life-threatening re-inspections, having the inspection supervisor ensure that each scheduled inspection is timely documented in the system, etc. Repeat Finding: No Views of responsible officials: Organization management agrees with the finding and recommendations set forth within. Refer to management’s corrective action plan for additional information.

2025-004 Suspension and Debarment 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury Passed through Florida Department of Environmental Protection 2024 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Documentation of the check for suspension or debarment needs to be retained. Condition: Review of checking for suspension and debarment was not done prior to contracting with the vendor. Cause of condition: The City did not consistently complete reviews for all vendors to ensure that the vendors were not suspended and debarred before projects had. Perspective (context): For 5 of the 8 vendors selected, suspension and debarment was not checked prior to paying the vendor. The sample was not statistically valid. Potential effect of condition: Good or services could be contracted with a suspended or debarred vendor, creating questioned costs. Questioned Costs: None noted. Reported finding is a deficiency in internal control. Recommendation: The City should require all vendors to provide certification of their status before a contract or purchase order is completed with the vendor and the City should obtain new certificates annually to ensure the vendors status has not changed. Management’s response on planned corrective action: Management agrees with the recommendation. The City has implemented procedures requiring all departments to obtain vendor certification of status prior to executing a contract or issuing a purchase order. Over the past year, we have worked diligently to educate departments on the importance of obtaining and maintaining proper vendor certifications to ensure compliance with applicable requirements. We will continue to reinforce this expectation and monitor compliance, including obtaining updated certifications annually to ensure vendor status has not changed.

2025-005 Lack of Report Review 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds US Department of Treasury 2021 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. Condition: There was no documented review by the City Manager of the annual report submitted to the Us Treasury department prior to submittal. Cause of condition: The annual report to the US Treasury was not reviewed prior to submittal. Perspective (context): The one annual report was not reviewed. Potential effect of condition: Review could contain errors, could be submitted incomplete or late. Questioned Costs: None noted. Reported finding is a deficiency in internal control. Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal. Management’s response on planned corrective action: Management agrees that reports should be reviewed prior to submission and notes that the City does have controls in place to ensure appropriate review procedures are performed. In this instance, the report was prepared and submitted by the City Manager, and due to limitations within the Federal Government’s online reporting system, there was not a built-in approval workflow available to document the review process.

Finding: 2025-001. Insufficient Controls Over Monitoring Federal Expenditures and SEFA Preparation Federal Agency: Federal Highway Administration Pass-through Agency: Texas Department of Transportation Assistance Listing Number: 20.205 Federal Program Name: Highway Planning and Construction Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.303 requires entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the awards. 2 CFR §200.501 requires a Single Audit when a non-Federal entity expends $1,000,000 or more in Federal awards during the current fiscal year (or $750,000 during the prior year). 2 CFR §200.510(b) requires the preparation of a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). Applicable GAAP requires recognition of grant revenue and related receivables when allowable expenditures are incurred. Condition: The City incurred reimbursable federal expenditures in the prior year but did not submit reimbursement requests or record the related receivable and revenue. As a result, certain federal expenditures were omitted from the SEFA, and total federal expenditures were understated below the $750,000 threshold for a Single Audit in the prior year. Cause: Grant administration is decentralized across multiple departments, and formal controls were not in place to reconcile grant expenditures to reimbursement requests or to monitor total federal expenditures and review the SEFA for completeness. Effect: Grant revenue and related receivables were understated, and the prior year SEFA was incomplete. As a result, the City did not include this grant award in the Single Audit in the prior year as required by Uniform Guidance. Questioned costs: N/A Context: N/A Repeat finding reference: N/A Recommendation: The City should strengthen oversight of federal grant activity by implementing procedures to monitor federal expenditures and ensure the SEFA is complete and accurate. This may include centralizing grant oversight within the finance function or designating a responsible grant administrator. Procedures should include periodic reconciliations of grant expenditures to reimbursement requests and a formal year-end review of total federal expenditures and the SEFA, with coordination between the finance function and departments administering federal programs. Personnel involved in grant administration should receive training on Uniform Guidance requirements. View of Responsible Officials Management’s response and corrective action plan are included in the accompanying corrective action plan.

Reviews of Grant Reports U.S. Department of Treasury ALN 21.027 - COVID 19 Coronavirus State and Local Fiscal Recovery Funds Contract No. Y5177 2021 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. Condition: There was no documented review by an independent individual for the reports submitted to the US Treasury department prior to submittal. Cause: The City did not have a process in place to document the review of reports to the US Treasury was prior to submittal. Effect: Reports submitted to the Florida Department of State may be incomplete, include errors, or be submitted late. Perspective: There was no evidence of review provided for the reports submitted during Fiscal Year 2025. Questioned Costs: None, reported finding is a deficiency in internal control. Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal and the review is documented. Management Response: Management agrees with the finding. Management will implement procedures to document independent review of all reports submitted to the U.S. Treasury to ensure completeness, accuracy, and timeliness.

2025-002 DISALLOWED COSTS ALN 97.083 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Federal Award No. EMW-2022-FF-00868 2024/2025 Funding Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain effective internal controls over federal awards. The award terms allow for reimbursement of personnel costs including wages, the employer portion of payroll taxes, and fringe benefits (health insurance, life insurance, and retirement benefits. Compensation for a firefighter’s normal, contracted work schedule is reimbursable, but overtime costs are not eligible for reimbursement by the SAFER grant award (including overtime for holdovers, extra shifts, to attend training, etc.). Only costs for overtime that the fire department routinely pays as a part of the base salary or a firefighter’s regularly scheduled and contracted shift hours, in order to comply with the Fair Labor Standards Act (FLSA), are eligible. Semi-annual financial reporting is required of all grant award recipients (per the award agreement terms). Condition: There was no independent review of reimbursement requests or semi-annual financial reports prior to submission to the grantor. Reimbursement requests included disallowed costs related to overtime (associated fringe benefits expense) but not the overtime itself. Additionally, semi-annual financial reports were based on reimbursement requests which resulted in reporting errors. Cause: There was no independent review of reimbursement requests or semi-annual financial reports prior to submission to the grantor. Effect: Lack of review increases the likelihood that reports are incomplete, inaccurate, or not submitted timely. Reimbursement requests and financial reports included errors and the City was inadvertently reimbursed for disallowable costs Questioned Costs: Known questioned costs are $10,551. Questioned costs computed through recalculation of fiscal year 2025 reimbursement requests. Perspective: Disallowed costs impacted all fiscal year 2025 reimbursement requests and semi-annual financial reports. Recommendation: Independent review of program reimbursement requests and reports should be consistently performed and documented prior to submission the grantor. Management Response: The City agrees with this finding and will establish internal procedures for review of program reimbursement requests before submission to the grantor. The Grant Compliance Manager will prepare the reimbursement requests and semi-annual reports and provide to the Director of Finance for review and approval prior to submission. This corrective action will take effect immediately.

2025-001 REPORTING ALN 20.106 Airport Improvement Program U.S. Department of Transportation Federal Aviation Administration Federal Award No. 3-12-0046-064-2024 2024/2025 Funding Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain effective internal controls over federal awards. The award terms require submission of quarterly construction and inspection reports within 30 days of the end of each Federal fiscal quarter. Condition: A quarterly report was not submitted for the period January 2025 – March 2025. Cause: The staff member who typically prepared the report was out on medical leave during this period. Effect: The Airport, a component unit of the City, was out of compliance with award requirements which could jeopardize its ability to be reimbursed for this award or obtain additional awards in the future. Questioned Costs: None. Reported finding is for noncompliance in the reporting compliance requirement that does not affect the amount expended or received for the federal award. Perspective: All other quarterly reports sampled were appropriately submitted timely. When we brought this issue to the attention of management they submitted the quarterly report late. Recommendation: The Airport, a component unit of the City, should develop a process to ensure reports are submitted timely for all awards including re-assigning tasks when personnel are on leave. Management Response: Airport management has set up a process whereby the quarterly reports are reviewed by another team member to ensure the reports are completed and submitted in the time frame required by the Federal Aviation Administration. This review will be completed by the Accounting Manager who understands the importance of submitting the information and, if they are not completed, will complete and submit the reports. Any issues or omissions observed by the Accounting Manager with submitting the required reports will be reported to the Director of Finance and Administration for further follow-up with the staff member who is primarily responsible for this task.

Year Finding Originated: 2025 Title and Assistance Listing Number of Federal Program: Staffing for Adequate Fire and Emergency Response 97.083 Federal Award Identification Number and Year: EMW-2022-FF-00974 Name of Federal Agency: Department of Homeland Security Questioned Costs: $13,801 Criteria: Per 2 CFR § 200.305, non-Federal entities must minimize the time between the transfer of federal funds and the disbursement of those funds for program purposes. Federal regulations and the SAFER grant terms require that reimbursement requests be based on allowable expenditures that have been incurred by the District. Additionally, 2 CFR § 200.303 requires non-Federal entities to establish and maintain effective internal controls over Federal awards to ensure compliance with Federal statutes, regulations, and terms and conditions of the Federal awards. Condition: During testing of SAFER reimbursement requests, one reimbursement request contained an error in the benefits calculation formula, resulting in the employer insurance costs being included twice in the request. The District received funds in excess of allowable costs incurred during the reimbursement period due to the calculation error. The District’s control designed to prevent such errors, management review and approval of SAFER reimbursement requests prior to submission, did not operate effectively. Although reimbursement requests are prepared and submitted by District personnel, documentation supporting management’s review and approval of the reimbursement calculations was not maintained, and the error in the reimbursement calculation was not detected prior to submission. Cause: The reimbursement request was prepared using a manual spreadsheet containing a formula error that duplicated certain benefit costs. The District’s reviewed procedures were not formally documented or designed to ensure the accuracy of reimbursement calculations prior to submission. Effect: The District requested and received federal funds in excess of allowable expenditures incurred during the reimbursement period. Additionally, the lack of effective review controls increases the risk that reimbursement requests may contain errors or unsupported amounts. Recommendation: We recommend that the District strengthen controls over reimbursement calculations and implement review procedures to ensure reimbursement requests are based solely on allowable costs incurred prior to submission. Views of responsible officials: See management’s response to finding on Page 59.