Findings Citing § 200.303

2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.

2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

2024-003 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) 40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. 2 CFR 200.303, 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 the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: In March 2024, the City implemented procedural changes to their certified payroll review process. Until February 2024, the City did not retain evidence to document the individual who reviewed the certified payroll for each week in which work was performed by construction contractors and subcontractors. Due to backlog, the City was not able to catch up on certifications until August 2024 which was after the fiscal year had ended. For fifty-four (54) of sixty (60) weeks of certified payroll submissions selected for testing, we noted that the City did not review the contractors’ submissions of certified payroll in a timely manner. For six (6) out of sixty (60) weeks of certified payroll submissions selected, we noted that a statement of non-performance was submitted. However, the tracking spreadsheet provided to the City by its 3rd party project manager indicated that work had been performed. For nineteen (19) out of sixty (60) weeks of certified payroll submissions selected, we noted that the contractor or subcontractor had not submitted the weekly certified payroll in a timely manner. The contractor had submitted their certified payroll several weeks after the week of work performed. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the accuracy of the tracking of work weeks being performed as well as the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective controls over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected sixty (60) out of all weeks indicated as work weeks for the City’s project for testing. However, due to the condition noted above, the population of work weeks could not be verified. Repeat Finding from the Prior Year(s): Yes, 2023-003. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.

U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Compliance and Internal Control Systems Over Compliance, Reporting Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: The Organization does not consistently utilize the accrual basis of accounting when creating requests for reimbursement of expenditures under federal grant awards. Cause: Internal controls over compliance as related to the compliance requirement of reporting were not designed and/or operating effectively. Effect: An organization is required to select a basis of accounting upon which to present the schedule of expenditures of federal awards (SEFA). This basis selected is disclosed to users of the financial statements as part of the notes to the SEFA. Inconsistent application of the basis of accounting used to support requests for reimbursement may result in a SEFA that is misstated relative to the basis of accounting selected by management and disclosed to users of the financial statements. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are recognized consistently on the basis of accounting selected by management (e.g., accrual vs. cash). Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology used was based on the reimbursement requests submitted throughout the year, which had been prepared on a cash basis. However, for the final reimbursement under the City of Las Vegas grant ending June 30, 2024, accrued payroll costs for work performed in June but paid in July were included to ensure full reporting of eligible grant activity. This deviation from the previously applied basis led to the noted inconsistency. Planned Corrective Actions: • Going forward, management will implement the following corrective actions: • A consistent accounting basis (accrual) will be selected and formally documented for all SEFA reporting and federal reimbursement requests. • Internal procedures will be updated to reflect the chosen basis and ensure it is applied uniformly across all reimbursement submissions. • A secondary review of SEFA reporting will be conducted by senior finance staff or the CEO to ensure consistency with the selected accounting method. • Staff will be trained annually on SEFA requirements and federal compliance standards under 2 CFR 200. These corrective actions will be completed by June 30, 2025.

U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Internal Control Systems Over Compliance, Allowable Costs Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: On the March 2024 request for reimbursement, the number of hours submitted for reimbursement for one employee was inconsistent with the supporting documentation included in the reporting package. The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Cause: Internal controls over compliance as related to the compliance requirement of allowable costs were not designed and/or operating effectively. Effect: The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Although the known or projected amount of this excess did not rise to the level of a questioned costs compliance finding, there is a risk that in the absence of a well-designed and consistently implemented system of internal controls that unallowable costs will be submitted for reimbursement. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are in accordance with allowable cost principles. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding regarding the discrepancy in reported hours for one employee on the March 2024 reimbursement request. The 16-hour variance was an unintentional clerical error during the preparation of the reimbursement package. The discrepancy was not material, but we agree that stronger controls are necessary to prevent such occurrences. Planned Corrective Actions: • To address this finding, management will: • Establish a formal review and approval process for all reimbursement packages, including verification of hours against supporting documentation (e.g., timesheets or payroll records). • Design and implement a checklist to be used during the preparation of reimbursement requests to ensure compliance with allowable cost principles. • Conduct periodic internal audits of submitted RFRs to confirm alignment with backup documentation. • Provide training to all relevant personnel on federal allowable cost requirements under 2 CFR 200. All corrective actions will be implemented by June 30, 2025, with ongoing monitoring thereafter.

U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Compliance and Internal Control Systems Over Compliance, Reporting Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: The Organization does not consistently utilize the accrual basis of accounting when creating requests for reimbursement of expenditures under federal grant awards. Cause: Internal controls over compliance as related to the compliance requirement of reporting were not designed and/or operating effectively. Effect: An organization is required to select a basis of accounting upon which to present the schedule of expenditures of federal awards (SEFA). This basis selected is disclosed to users of the financial statements as part of the notes to the SEFA. Inconsistent application of the basis of accounting used to support requests for reimbursement may result in a SEFA that is misstated relative to the basis of accounting selected by management and disclosed to users of the financial statements. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are recognized consistently on the basis of accounting selected by management (e.g., accrual vs. cash). Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology used was based on the reimbursement requests submitted throughout the year, which had been prepared on a cash basis. However, for the final reimbursement under the City of Las Vegas grant ending June 30, 2024, accrued payroll costs for work performed in June but paid in July were included to ensure full reporting of eligible grant activity. This deviation from the previously applied basis led to the noted inconsistency. Planned Corrective Actions: • Going forward, management will implement the following corrective actions: • A consistent accounting basis (accrual) will be selected and formally documented for all SEFA reporting and federal reimbursement requests. • Internal procedures will be updated to reflect the chosen basis and ensure it is applied uniformly across all reimbursement submissions. • A secondary review of SEFA reporting will be conducted by senior finance staff or the CEO to ensure consistency with the selected accounting method. • Staff will be trained annually on SEFA requirements and federal compliance standards under 2 CFR 200. These corrective actions will be completed by June 30, 2025.

U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Internal Control Systems Over Compliance, Allowable Costs Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: On the March 2024 request for reimbursement, the number of hours submitted for reimbursement for one employee was inconsistent with the supporting documentation included in the reporting package. The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Cause: Internal controls over compliance as related to the compliance requirement of allowable costs were not designed and/or operating effectively. Effect: The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Although the known or projected amount of this excess did not rise to the level of a questioned costs compliance finding, there is a risk that in the absence of a well-designed and consistently implemented system of internal controls that unallowable costs will be submitted for reimbursement. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are in accordance with allowable cost principles. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding regarding the discrepancy in reported hours for one employee on the March 2024 reimbursement request. The 16-hour variance was an unintentional clerical error during the preparation of the reimbursement package. The discrepancy was not material, but we agree that stronger controls are necessary to prevent such occurrences. Planned Corrective Actions: • To address this finding, management will: • Establish a formal review and approval process for all reimbursement packages, including verification of hours against supporting documentation (e.g., timesheets or payroll records). • Design and implement a checklist to be used during the preparation of reimbursement requests to ensure compliance with allowable cost principles. • Conduct periodic internal audits of submitted RFRs to confirm alignment with backup documentation. • Provide training to all relevant personnel on federal allowable cost requirements under 2 CFR 200. All corrective actions will be implemented by June 30, 2025, with ongoing monitoring thereafter.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Equipment Property Management Federal Program: Congressional Directives (ALN 93.493) Federal Agency: Department of Health and Human Services Federal Award Number: 1CE1HS52890-01-00 Federal Award Year: September 30, 2023 through June 30, 2024 Criteria or Requirement Per 2 CFR section 200.313, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Per 2 CFR 200.303, 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. Condition and Context For 4 out of 14 purchase transactions or 17 out of 20 individual assets, equipment exceeding the capitalization threshold per 2 CFR section 200.1 was not capitalized. Therefore, a property record did not exist for federally funded equipment purchased in the amount of $1,758,365. The total program expenditures were $3,652,263 for which $2,776,884 were capital equipment purchases and $875,379 were non-capital purchases. For the equipment that was capitalized and a property record was established, the property record did not properly identify the asset as federally funded. Cause and Potential Effect The University's internal controls for determining and documenting whether an equipment acquisition was a capital asset for which a property record should be created in the system with the required was not operating effectively. Accordingly, the University acquired federally funded equipment and a property record was not created. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over equipment purchases to ensure that a property record is created within the system containing the required information for all federally funded equipment. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Period of Performance Federal Program: Research and Development Cluster - Arthritis, Musculoskeletal and Skin Diseases Research (ALN 93.846) Federal Agency: Department of Health and Human Services Federal Award Number: R01AR071410 Federal Award Year: July 1, 2023 through June 30, 2024 Criteria or Requirement Per 2 CFR section 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Per 2 CFR 200.303, 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. Condition and Context For 1 of 40 transactions sampled for period of performance, purchase incurred after the period of performance was charged to the grant which is not allowable under the grant award or cost principles. Cause and Potential Effect The University's internal controls for determining a purchase is within the federal award’s period of performance was not operating effectively. Accordingly, the University has requested reimbursement for purchases incurred after the period of performance of the federal award. Questioned Cost There are known questioned costs of $16,017. The aggregated total sample for the 40 period of performance transactions was $2,132,385. The total population for research and development cluster expenditures aggregated $184,508,852. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over purchases to ensure the purchases are incurred within the federal award’s period of performance and if incurred subsequent to the federal award’s period of performance, are not charged to the federal agency. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

Finding 2024-005 U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: 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. Condition and Context: For 3 out of 40 selections, the County was unable to provide copies of the invoices selected to support the expense paid with grant funds. Cause: The County did not implement the controls in place to ensure all the invoices are retained properly. Effect or Potential Effect: The County may not be in compliance with Uniform Guidance. Questioned Costs: $2,315.84 Recommendation: We recommend that the County implement improvements to its policies and procedures to ensure documents are retained in accordance with its retention policy. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report

2024-001: PROVISIONS OF THE DAVIS-BACON ACT Program: Federal Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), Significant Deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Repeat Finding: No. Condition/Context: During our testing on one of 1 contractor, we noted the District did not have adequate internal controls designed to ensure contractors were in compliance with applicable Davis-Bacon Wage Rate requirements. The District did not retain documentation supporting indication of certified payrolls being submitted in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by Impact Aid. In addition, contracts or purchase orders were not documented to support the need for compliance under Davis Bacon. Criteria or Specific Requirement: The Davis-Bacon Act requires that laborers and mechanics employes by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly per 29 CFR 5.5 compliance provisions. Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control 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 comply with guidance in “Standards for Internal Control in 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: The District’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors were monitored for compliance. Effect: Noncompliance and internal control weakness. Recommendation: We recommend the District implement policies and procedures to ensure effective monitoring of compliance with Davis-Bacon wage requirements.

FINDING 2024-003 Subject: COVID-19 - Emergency Connectivity Fund Program - Special Tests and Provisions - Restricted Purpose Federal Agency: Federal Communications Commission Federal Program: COVID-19 - Emergency Connectivity Fund Program Assistance Listings Number: 32.009 Federal Award Number and Year (or Other Identifying Number): FY23 Compliance Requirement: Special Tests and Provisions - Restricted Purpose Audit Finding: Material Weakness Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to asset inventory and per-user limitations of the devices purchased with Emergency Connectivity Fund (ECF) Program support. The School Corporation maintained an asset inventory for the purchased equipment; however, the data was input into the asset listing, from the equipment invoice by the Information Technology department without a documented review or oversight process to prevent, or detect and correct, errors. In addition, there was not a documented review or oversight process to ensure each student only received one device. The lack of internal controls was systemic throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 22 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure that students only received one device. Evidence of another individual reviewing the student inventory listing was not provided, so there was nothing to show there was an internal control over this compliance requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Restricted Purpose compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-004 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 23 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not designed or implemented an effective internal control system over the Eligibility compliance requirement. Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. The counts that are prepopulated should be based on the School Corporation's records as of October of the prior fiscal year. During the audit period, the School Corporation submitted two Title I Applications. The School Corporation was required to use the October 2021 Real Time Report data for the 2022-2023 Title I application and the October 2022 Real Time Report data for the 2023-2024 Title I Application submitted to the IDOE. Data to be submitted included student socioeconomic status information. The October 2021 and 2022 reports were available for review and the Title I Director cross checks the information in the Title I application with the October enrollment and poverty rates at each school from the Certification Summary reports; however, no other school personnel verifies the Title I numbers on the application. Additionally, the nonpublic school sends its annual enrollment and poverty counts to the Title I Director, but the Title I Director does not verify these student numbers are accurate. The Title I Director does verify the student addresses are within the district, but she does not verify the enrollment and poverty are correct. The lack of internal controls was systemic 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 by management of the School Corporation to ensure enrollment and poverty rates were properly reported on the Title I application. Effect Without an effective internal control system, including segregation of duties, the School Corporation is at risk for noncompliance with the grant agreement and the Eligibility compliance requirement. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 24 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls over Real Time reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-004 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 23 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation had not designed or implemented an effective internal control system over the Eligibility compliance requirement. Eligibility for Title I is determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers are automatically pulled from the Indiana Department of Education's (IDOE) Official Pupil Enrollment (PE) count for each school into the Eligible School Summary page of the Title I application. The counts that are prepopulated should be based on the School Corporation's records as of October of the prior fiscal year. During the audit period, the School Corporation submitted two Title I Applications. The School Corporation was required to use the October 2021 Real Time Report data for the 2022-2023 Title I application and the October 2022 Real Time Report data for the 2023-2024 Title I Application submitted to the IDOE. Data to be submitted included student socioeconomic status information. The October 2021 and 2022 reports were available for review and the Title I Director cross checks the information in the Title I application with the October enrollment and poverty rates at each school from the Certification Summary reports; however, no other school personnel verifies the Title I numbers on the application. Additionally, the nonpublic school sends its annual enrollment and poverty counts to the Title I Director, but the Title I Director does not verify these student numbers are accurate. The Title I Director does verify the student addresses are within the district, but she does not verify the enrollment and poverty are correct. The lack of internal controls was systemic 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 by management of the School Corporation to ensure enrollment and poverty rates were properly reported on the Title I application. Effect Without an effective internal control system, including segregation of duties, the School Corporation is at risk for noncompliance with the grant agreement and the Eligibility compliance requirement. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 24 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation establish a proper system of internal controls over Real Time reports. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not designed or implemented an effective internal control system over the Matching, Level of Effort, Earmarking compliance requirement. Earmarking A portion of the School Corporation's Title I allocation was required to be set aside for homeless reservation. The required amount to be set aside was indicated in the Title I grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did have a review process in place to ensure monitoring of each required set aside; however, it was not effective in preventing or detecting noncompliance. The School Corporation did not meet the obligation to service all the homeless students in the School Corporation for fiscal year 2022-2023 and did not transfer the unused funds to the next grant award. Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. The School Corporation did not have an oversight process in place to ensure that expenditures were properly recorded on the Form 9. INDIANA STATE BOARD OF ACCOUNTS 25 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 6313(c)(3)(A) states: "A local educational agency shall reserve such funds as are necessary under this part, determined in accordance with subparagraphs (B) and (C), to provide services comparable to those provided to children in schools funded under this part to serve - (i) homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live; (ii) children in local institutions for neglected children; and (iii) if appropriate, children in local institutions for delinquent children, and neglected or delinquent children in community day programs." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure earmarking was followed for the homeless reservation and expenditures were properly recorded on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the obligations for homeless reservation was not met and potential noncompliance could have occurred with Form 9 reporting. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure compliance. INDIANA STATE BOARD OF ACCOUNTS 26 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION 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.

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not designed or implemented an effective internal control system over the Matching, Level of Effort, Earmarking compliance requirement. Earmarking A portion of the School Corporation's Title I allocation was required to be set aside for homeless reservation. The required amount to be set aside was indicated in the Title I grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did have a review process in place to ensure monitoring of each required set aside; however, it was not effective in preventing or detecting noncompliance. The School Corporation did not meet the obligation to service all the homeless students in the School Corporation for fiscal year 2022-2023 and did not transfer the unused funds to the next grant award. Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the books and records of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. The School Corporation did not have an oversight process in place to ensure that expenditures were properly recorded on the Form 9. INDIANA STATE BOARD OF ACCOUNTS 25 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 6313(c)(3)(A) states: "A local educational agency shall reserve such funds as are necessary under this part, determined in accordance with subparagraphs (B) and (C), to provide services comparable to those provided to children in schools funded under this part to serve - (i) homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live; (ii) children in local institutions for neglected children; and (iii) if appropriate, children in local institutions for delinquent children, and neglected or delinquent children in community day programs." Cause A proper system of internal controls was not designed by management of the School Corporation to ensure earmarking was followed for the homeless reservation and expenditures were properly recorded on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the obligations for homeless reservation was not met and potential noncompliance could have occurred with Form 9 reporting. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure compliance. INDIANA STATE BOARD OF ACCOUNTS 26 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION 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.

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Special Tests and Provisions - Annual Report Card compliance requirement. The School Corporation did not have effective internal controls in place to ensure that documentation regarding the reason for a student being removed from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. The Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement necessitated that for students removed from the high school graduation cohort for mobility reasons there be proper written documentation to support the identified mobility code. There were 15 students selected for testing. Of the 15 students tested, 1 student did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. The lack of internal controls, noncompliance, and failure to maintain adequate supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 27 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Due to an ineffective internal control system, documentation was not maintained to provide evidence of proper removal of a student from a cohort. Effect Without the proper design or implementation of internal controls, material noncompliance cannot be capable of being prevented or detected and corrected. As a result, proper documentation to support students' mobility was not collected, retained, or provided for audit. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure mobility documentation is collected and retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Special Tests and Provisions - Annual Report Card compliance requirement. The School Corporation did not have effective internal controls in place to ensure that documentation regarding the reason for a student being removed from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. The Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement necessitated that for students removed from the high school graduation cohort for mobility reasons there be proper written documentation to support the identified mobility code. There were 15 students selected for testing. Of the 15 students tested, 1 student did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. The lack of internal controls, noncompliance, and failure to maintain adequate supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 27 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Due to an ineffective internal control system, documentation was not maintained to provide evidence of proper removal of a student from a cohort. Effect Without the proper design or implementation of internal controls, material noncompliance cannot be capable of being prevented or detected and corrected. As a result, proper documentation to support students' mobility was not collected, retained, or provided for audit. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure mobility documentation is collected and retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Supplement Not Supplant Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 28 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Supplement Not Supplant compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that all Title I schools received an equitable share of the state and local funds that it would have received had they not been receiving Title I funds. The Title I applications included the methodology used to distribute state and local funds to all schools within the School Corporation and documentation was presented for audit that reflected the actual calculation. 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 by management of the School Corporation to ensure all Title I schools received an equitable share of the state and local funds that it would have received had they not been receiving Title I funds. Effect Without an effective internal control system, including segregation of duties, the School Corporation is at risk for noncompliance with the grant agreement and the Supplement Not Supplant compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Supplement Not Supplant compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 29 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION 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.

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Supplement Not Supplant Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 28 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Supplement Not Supplant compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that all Title I schools received an equitable share of the state and local funds that it would have received had they not been receiving Title I funds. The Title I applications included the methodology used to distribute state and local funds to all schools within the School Corporation and documentation was presented for audit that reflected the actual calculation. 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 by management of the School Corporation to ensure all Title I schools received an equitable share of the state and local funds that it would have received had they not been receiving Title I funds. Effect Without an effective internal control system, including segregation of duties, the School Corporation is at risk for noncompliance with the grant agreement and the Supplement Not Supplant compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Supplement Not Supplant compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 29 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION 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.

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Assessment System Security Audit Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that all Title I Assessment System Security was in place. Some testing security training lists occasionally contained names which were printed and signed by the school employee taking the training. These lists were not subsequently reviewed to verify everyone who should have taken the training were included. The lists were requested to be sent to the School Corporation offices to be on file. However, they were not reviewed. 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 by management of the School Corporation to ensure required school employees took the training. INDIANA STATE BOARD OF ACCOUNTS 30 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance over the Special Test and Provisions - Assessment System Security compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Assessment System Security Audit Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that all Title I Assessment System Security was in place. Some testing security training lists occasionally contained names which were printed and signed by the school employee taking the training. These lists were not subsequently reviewed to verify everyone who should have taken the training were included. The lists were requested to be sent to the School Corporation offices to be on file. However, they were not reviewed. 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 by management of the School Corporation to ensure required school employees took the training. INDIANA STATE BOARD OF ACCOUNTS 30 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance over the Special Test and Provisions - Assessment System Security compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Participation of Private School Children Audit Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Participation of Private School Children compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that a review of all Title I Participation of Private School Children expenses was in place. 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: INDIANA STATE BOARD OF ACCOUNTS 31 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 by management of the School Corporation to ensure that an evident review of all Participation of Private School Children expenses was performed. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance over the Special Test and Provisions - Participation of Private School Children compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Participation of Private School Children compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Participation of Private School Children Audit Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Participation of Private School Children compliance requirement. The School Corporation was unable to provide evidence of an internal control being in place to ensure that a review of all Title I Participation of Private School Children expenses was in place. 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: INDIANA STATE BOARD OF ACCOUNTS 31 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 by management of the School Corporation to ensure that an evident review of all Participation of Private School Children expenses was performed. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance over the Special Test and Provisions - Participation of Private School Children compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Participation of Private School Children compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-010 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-027-PN01, 22611-027-ARP, 22619-027-ARP, 23611-027-PN01, 23619-027-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not established an effective internal control system related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 32 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During our testing, there were two employees being paid a higher rate per hour for training from the Special Education grant funds. The rate was higher than the normal hourly rate. The rate for the training hours was a stipend rate set by the school for paraprofessional training. There was no authorization by the School Corporation Officials for the rate change between the regular rate and a professional development training rate. The Indiana Department of Education did not approve the separate rate. Other noncompliance involved three employees tested. The School Corporation used accounting software to process payroll. The software calculated payroll tax based on the employee year-to-date salary rather than calculating tax on gross pay per period. The lack of internal controls and noncompliance were isolated to the transactions as described above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 34 CFR 76.700 states: "A State and a subgrantee shall comply with § 76.500, the State plan, applicable statutes, regulations, and approved applications, and shall use Federal funds in accordance with those statutes, regulations, plan, and applications." Cause The internal control system over the Allowable Costs/Cost Principles compliance requirement was not effective in preventing or detecting the overpayment of employees. INDIANA STATE BOARD OF ACCOUNTS 33 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, the overpayment of employees was not caught by another employee at the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure payroll applicable to the grant agreement complies with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-010 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-027-PN01, 22611-027-ARP, 22619-027-ARP, 23611-027-PN01, 23619-027-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not established an effective internal control system related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 32 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During our testing, there were two employees being paid a higher rate per hour for training from the Special Education grant funds. The rate was higher than the normal hourly rate. The rate for the training hours was a stipend rate set by the school for paraprofessional training. There was no authorization by the School Corporation Officials for the rate change between the regular rate and a professional development training rate. The Indiana Department of Education did not approve the separate rate. Other noncompliance involved three employees tested. The School Corporation used accounting software to process payroll. The software calculated payroll tax based on the employee year-to-date salary rather than calculating tax on gross pay per period. The lack of internal controls and noncompliance were isolated to the transactions as described above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 34 CFR 76.700 states: "A State and a subgrantee shall comply with § 76.500, the State plan, applicable statutes, regulations, and approved applications, and shall use Federal funds in accordance with those statutes, regulations, plan, and applications." Cause The internal control system over the Allowable Costs/Cost Principles compliance requirement was not effective in preventing or detecting the overpayment of employees. INDIANA STATE BOARD OF ACCOUNTS 33 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, the overpayment of employees was not caught by another employee at the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure payroll applicable to the grant agreement complies with the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.