Findings Citing § 200.305

1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.

Federal Program – American Rescue Plan Technical Assistance Investment Program – Assistance Listing No. 10.234 – Award No. 2023-70504-40441 – Program Year 2024– U.S. Department of Agriculture Criteria or specific requirement – Cash Management, 2 CFR 200.305 Condition – The organization is required to minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient or the subrecipients in accordance with 2 CFR 200.305. If the organization cannot meet the requirements for advance payment, they must use the reimbursement method. The organization, as a pass-through entity, is also responsible for implementing procedures to ensure the time elapsing between the transfer of Federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient is minimized in accordance with 2 CFR section 200.305(b)(1). Cause – The organization did not have appropriate controls in place to ensure compliance with federal requirements to minimize the time elapsing between receiving and disbursing the federal funds. The organization also did not have appropriate controls in place to ensure the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of funds by the subrecipient for program purposes was minimized. Effect – The organization drew funds, but did not disburse them in a timely manner. Additionally, they passed funds to subrecipients and did not ensure the subrecipients spent those funds timely. Questioned costs – Assistance Listing No. 10.234, FAIN No. 20237050440441: $2,855,333. The amount calculated represents the total federal funding the organization received in advance that had not been expensed for program purposes by the end of the reporting period. Assistance Listing No. 10.234: $741,517. The amount calculated represents the total amount of federal funds passed through to subrecipients for the reporting period. Context – There were no cash draws for the reporting period as the majority of the funding awarded was received in advance in the prior year. Out of a population of 8 subrecipients, 2 subrecipients were selected for testing. Of these subrecipients, both received funding in advance; however, both did not disburse funds under the program purposes within a timely manner. Our sample was not, and was not intended to be, statistically valid. Identification as a repeat finding, if applicable – N/A Recommendation – The organization should put controls in place to ensure that funds are requested and spent timely or move to the reimbursement basis. The organization should put controls in place to ensure that funds passed through to subrecipients are disbursed by the subrecipient for the program within a timely manner. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. Management plans to revise internal procedures to include verification of expenditures for eligible and allowable expenses before initiating a draw request, develop a drawdown checklist and require supporting documentation for incurred costs, retain supporting documentation for all drawdowns, require Executive Director approval prior to all federal drawdowns, and conduct training on federal reimbursement protocols for program and finance staff.

2024 -003 – CASH MANAGEMENT Significant Deficiency / Other Matter U.S. Department of Housing and Urban Development ALN #: 14.872 – Public Housing Capital Fund CRITERIA For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. (2 CFR 200.305 (b)) Once funds are disbursed, i.e. transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days after the deposit of the funds into the PHA’s bank account. (HUD Capital Fund Guidebook; Section 7.9) CONDITION We selected a sample of 4 drawdowns of capital funds from ELOCCs during the year. We identified 1 instance in which the Authority did not process payment to the vendor within 3 business days of receiving the funds. CAUSE The Authority does not have sufficient procedures in place to coordinate the timing of drawdowns with disbursement schedules. EFFECT Federal funds were held in excess of immediate cash requirements, which is not in compliance with Uniform Guidance cash management requirements. QUESTIONED COSTS None Identified. CONTEXT The Authority had 8 drawdowns of capital funds during the year. We selected a sample of 4 drawdowns during the year. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority utilize the reimbursement method and process payment to the vendor before requisitioning funds from ELOCCs. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Assistance Listing Number: 93.193 Name of Federal Program: COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2024 – December 31, 2024 Criteria or Specific Requirement: Per 2 CFR Part 200, non-federal entities receiving federal awards must establish and maintain written policies and procedures addressing areas including, but not limited to: procurement (§200.317–§200.327); travel costs (§200.475); methods for avoiding duplication of costs (§200.403); subrecipient monitoring (§200.332); cash management and allowable costs (§200.302, §200.305). Condition: The organization has not implemented all policies and procedures required under the Uniform Guidance. Specifically, certain written policies and procedures required by 2 CFR Part 200, such as cash management, allowability of costs, equipment management, conflict of interest, procurement, travel, compensation, and fringe benefits, were either incomplete, not formally documented, or not in place during the audit period. Cause: The Council has not detailed its policies to conform with the requirements of the Uniform Guidance. Effect or Potential Effect: Without documented and implemented policies and procedures, the organization increases the risk of noncompliance with federal regulations, inconsistent application of requirements, unallowable costs being charged to federal awards, and potential questioned costs or sanctions from funding agencies. Repeat Finding: No Recommendation: Management should develop, formally adopt, and implement all required Uniform Guidance policies and procedures. Policies should be documented, communicated to relevant staff, and periodically reviewed to ensure ongoing compliance. Views of Responsible Officials: Management agrees with the finding and revise its policies and procedures to meet the criteria of the Uniform Guidance.

Assistance Listing Number: 93.193 Name of Federal Program: COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2024 – December 31, 2024 Criteria or Specific Requirement: Per 2 CFR Part 200, non-federal entities receiving federal awards must establish and maintain written policies and procedures addressing areas including, but not limited to: procurement (§200.317–§200.327); travel costs (§200.475); methods for avoiding duplication of costs (§200.403); subrecipient monitoring (§200.332); cash management and allowable costs (§200.302, §200.305). Condition: The organization has not implemented all policies and procedures required under the Uniform Guidance. Specifically, certain written policies and procedures required by 2 CFR Part 200, such as cash management, allowability of costs, equipment management, conflict of interest, procurement, travel, compensation, and fringe benefits, were either incomplete, not formally documented, or not in place during the audit period. Cause: The Council has not detailed its policies to conform with the requirements of the Uniform Guidance. Effect or Potential Effect: Without documented and implemented policies and procedures, the organization increases the risk of noncompliance with federal regulations, inconsistent application of requirements, unallowable costs being charged to federal awards, and potential questioned costs or sanctions from funding agencies. Repeat Finding: No Recommendation: Management should develop, formally adopt, and implement all required Uniform Guidance policies and procedures. Policies should be documented, communicated to relevant staff, and periodically reviewed to ensure ongoing compliance. Views of Responsible Officials: Management agrees with the finding and revise its policies and procedures to meet the criteria of the Uniform Guidance.

2024-002 Noncompliance with Cash Management (Public Housing Capital Fund ALN 14.872) Criteria: Federal Code of Regulations, 2 CFR § 200.305 requires the Authority to maintain both written procedures that minimize the time elapsing between the transfer of funds from HUD and disbursement of those funds for eligible costs and financial management systems that meet the standards for fund control and accountability. Advance payments to the Authority must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the Authority in its Capital Fund Program. Furthermore, in accordance with 2 CFR § 905.310, the Authority shall initiate a fund requisition from HUD only when funds are due and payable, unless HUD approves another payment schedule as authorized by 2 CFR 200.305. The Capital Fund Program rules provide guidelines of 3 business days from drawdown to expenditure. Condition: During the year, the Authority had 12 transactions in its Capital Fund Program for grants ranging from CFP 2020-2022 that did not adhere to the requirements to minimize the time federal funds were drawn down to expenditures of 3 business days. Questioned Costs: None. Effect: The Authority did not properly follow the requirements of 2 CFR § 200.305 and 905.310. Cause: The Authority did not have an adequate understanding of the Capital Fund Program requirements as related to Cash Management. Recommendation: The Authority’s staff should familiarize themselves with Capital Fund Program rules and guidelines in relation to Cash Management. Management Response: Management was unaware of the Cash Management rules and guidelines of the Authority’s Capital Fund Program. We will ensure all future eligible Capital Fund draws are made within 3 business days of expenditures.

2024-002 – HUD CAPITAL FUND PROGRAM (CFDA #14.872) DRAWDOWNS Federal Program Name: Capital Fund Program Assistance Listing Number: 14.872 Federal Agency: U.S. Department of Housing and Urban Development Compliance Requirement: Cash Management Criteria: Per HUD Capital Fund Program guidance and 2 CFR 200.305(b) (Cash Management), PHAs must minimize the time between the drawdown of federal funds and disbursement to vendors. HUD guidance further states: “Once funds are disbursed, i.e., transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days. PHAs cannot expend nonfederal funds first to pay the applicable bills and then use Capital Funds to reimburse themselves.” Condition: During our testing of Capital Fund drawdowns, we identified three drawdown transactions where the PHA did not comply with the 3-day rule. In each case, vendor payments were made prior to funds being received. Cause: Oversight Effect: The PHA is not in compliance with HUD’s cash management rules for Capital Fund drawdowns. Repeat Finding: No Recommendation: We recommend the PHA establish procedures requiring that Capital Fund related vendor invoices not be paid until drawdowns have occurred.

Criteria: In accordance with the Uniform Guidance (2 CFR §200.305), when entities are funded on a reimbursement basis, they must disburse funds for program purposes prior to requesting reimbursement. The grant for IBBG allowed a 3 day grace period where the Organization could request funds in advance if they spend them within 3 days. Condition: During our testing of cash management, we noted that the Organization requested and received reimbursement of federal funds prior to expending the related program costs. In a certain instance the entity also requested funds in advance and did not spend them within the 3 day window. Cause: The Organization did not have adequate procedures in place to ensure reimbursement requests were timed in accordance with federal cash management requirements. Effect: Requesting federal funds in advance of need results in noncompliance with cash management requirements and creates a risk of the Organization holding federal funds for unallowable purposes, or earning interest that would need to be remitted to the Federal government. Questioned Costs: None. Recommendation: We recommend that the Organization strengthen its cash management procedures to ensure that reimbursement requests are made only after expenditures have been incurred, and that advance requests, if any, are timed so that funds are disbursed within the required three-day window. Organization Response: Management agrees with this finding.

Criteria or Specific Requirement: Per 2 CFR §200.302, nonfederal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance of compliance with applicable federal statutes, regulations, and the terms and conditions of the award. • Cash Management requirements under 2 CFR §200.305 require that drawdowns be based on allowable costs incurred, supported by documentation, and reviewed for accuracy prior to submission. • Matching requirements under 2 CFR §200.306 require that cost sharing or matching contributions be verifiable from the entity’s records and documented in accordance with the cost principles. Entities must retain written documentation of the review and approval process before submission of reimbursement requests to ensure accuracy and compliance. Condition: The Organization maintained a written cash management policy; however, the policy did not specify that documentation of review and approval of reimbursement requests must be retained. As a result, the Organization was unable to provide written evidence of review and approval prior to submission of certain reimbursement requests. In addition, the Organization did not have a formal written policy addressing the review, approval, and documentation of matching contributions to ensure they are allowable, verifiable, and in compliance with federal requirements. While management indicated that a review process occurs, the lack of documented approval reduces the audit trail and does not provide adequate evidence that costs included in the requests were reviewed for accuracy, allowability, and compliance with both cash management and matching requirements. Cause: The lack of specificity in the cash management policy regarding retention of documented approvals, combined with the absence of a written matching policy, resulted in a lack of written documentation of the review and approval process that could be verified. Effect or Potential Effect: Without documented approval for reimbursement requests or a formal policy over matching, there is an increased risk that unallowable or unsupported costs could be included in reimbursement requests or that matching contributions could be inaccurately reported, potentially resulting in noncompliance with federal requirements. Questioned Costs: Not applicable as there were no questioned costs related to noncompliance. Recommendation: We recommend the Organization strengthen its internal controls over cash management and matching by implementing the following: 1. Update the cash management policy to require documented review and approval of reimbursement requests, with such documentation retained as part of the grant record. 2. Develop and implement a formal written matching policy that includes procedures for review, approval, and documentation of matching contributions to ensure compliance with 2 CFR §200.306. Repeat finding from prior year: No – this is the Organization’s first single audit. Views of Responsible Officials: Management agrees with the finding. See attached corrective action plan.

Finding 2024-003 – Subrecipient Cash ManagementIdentification of the federal program:Federal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 12.420, Military Medical Research and DevelopmentGrant Award: W81XWH2010210Federal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.395, Cancer Treatment ResearchGrant Award: R01CA248574Federal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural ResearchGrant Award: R01DK133328Criteria or specific requirement (including statutory, regulatory or other citation):Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”2 CFR 200.305 (c) states, “…the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.”Condition:Management did not have sufficiently designed internal controls to ensure all payments made to subrecipients were made within the required time frames.Cause:Management did not ensure that all subrecipient cash payments were made within the required time frame.Effect or potential effect:Subrecipients are not paid within the time frame established in the Uniform Guidance.Questioned costs:None.Context:We tested a sample of 10 subrecipient payments, and identified 4 payments that were not paid within 30 days of receipt. Total expenditures for the Research and Development Cluster were $13,427,764 at December 31, 2024. Total subrecipient expenditures for the year ended December 31, 2024, were $2,133,172.Identification as a repeat finding, if applicable:This finding is not a repeat finding from the prior year.Recommendation:Management should ensure subrecipient payments are made within the required time frames included in the Uniform Guidance.Views of responsible officials:Management concurs with the finding and will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3), including review of current processes, policies, and procedures to minimize the time between invoice receipt and the transfer of federal funds to the subrecipient.

Finding 2024-003 Material Weakness in Controls over Compliance and Material Noncompliance – Cash Management Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Criteria – In accordance with 2 CFR 200.305 when non-federal entities are funded under the reimbursement method, expenditures should be incurred prior to the date of the reimbursement request. Condition/Perspective – There were four drawdowns made in relation to the fiscal year 2024 expenses for the grant. For two out of the four drawdowns, management erroneously drew down in excess of the expenses incurred. Cause – When requesting for drawdowns management erroneously used the cumulative expenses in the underlying spreadsheet rather than the periodic expenses which led to draw downs to be in excess of the expenses. Questioned Cost - $732,156 was over drawn. Effect – Drawing down in excess of the expenses incurred may result in the granting agency withholding future funding for this grant. Recommendation – Implement a more precise control to ensure that the underlying expense details that are used to make the drawdowns made are accurately calculated. View of Responsible Officials - See Corrective Action Plan

Finding 2024-001 – Cash Management – Pass-Through Entities Identification of the federal program: U.S. Department of Health and Human Services U.S. Department of Defense Research and Development Cluster All Assistance Listing Numbers with amounts provided to subrecipients: 12.420 – Military Medical Research and Development 93.242 – Mental Health Research Grants 93.279 – Drug Abuse and Addiction Research Programs 93.351 – Research Infrastructure Programs 93.838 – Lung Diseases Research 93.855 – Allergy and Infectious Diseases Research 93.866 – Aging Research Federal Award Numbers Award Period W81XWH1910496-02 5/1/2020-10/31/2025 R01MH116844-05 2/1/2022-1/31/2024 R01MH130193-02 3/1/2023-2/29/2024 R01MH130193-03 3/1/2024-2/28/2025 R01DA052845-04 7/1/2023-6/30/2024 U42OD010442-22 2/1/2023-1/31/2024 P51OD011133-25 5/1/2023-4/30/2024 P51OD011133-26 5/1/2024-4/30/2025 R01HL145411-05 1/1/2023-12/31/2025 R01AI048071-21 12/1/2022-11/30/2023 R01AI048071-22 12/1/2023-1/31/2025 R01AI138587-05 5/1/2022-4/30/2025 R01AI172539-02 8/1/2023-7/31/2024 1503702001-03 8/1/2024-7/31/2025 R21AI170148-02 8/1/2023-7/31/2025 R01AI134245-07 5/1/2023-4/30/2025 P30AI168439-02 3/1/2023-2/29/2024 P30AI168439-03 3/1/2024-2/28/2025 R61AI169026-02 5/1/2023-4/30/2024 R61AI169026-03 5/1/2024-4/30/2026 R56AI174877-01 4/1/2023-3/31/2025 Federal Award Numbers Award Period R01AI176309-01 4/1/2023-3/31/2024 R01AI176309-02 4/1/2024-3/31/2025 R01AI158963-03 4/1/2024-3/31/2025 R01AI179465 6/21/2024-4/30/2025 U34AG068482-03 6/1/2022-5/31/2025 R01AG065546-04 6/1/2023-5/31/2024 R01AG065546-05 6/1/2024-5/31/2025 Criteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.305(b)(1) requires “The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions.” 2 CFR 200.305(b)(3) requires “when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper.” Condition Texas Biomedical Research Institute (Texas Biomed) did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days of requests for reimbursement received by Texas Biomed. In 18 instances, Texas Biomed paid subrecipients after 30 days of receipt of the request for reimbursement from the subrecipient, resulting in noncompliance with 2 CFR 200.305(b)(3). Cause Texas Biomed’s internal controls around payments to subrecipients were not precisely designed to ensure the issuance of payments to subrecipients occurs within 30 days of requests for reimbursement by the subrecipient. Effect or potential effect Texas Biomed did not comply with the cash management requirements of the Uniform Guidance to pay subrecipients within 30 days of their requests for reimbursement. Questioned costs None. Context EY issued a significant deficiency for Texas Biomed related to internal controls over cash management for subrecipients in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a significant deficiency consistent with the prior year finding. For 18 of 40 subrecipient payments to 13 unique subrecipients, Texas Biomed made payments to subrecipients at dates ranging from 31 to 109 days (average of 64 days) after receipt of the requests for reimbursement. These payments were not made in accordance with the 30-day requirement for the following award numbers: • R01MH116844-05 • R01AG065546-04 (3 late payments) • P30AI168439-02 • R56AI174877-01 (2 late payments) • R01AI176309-02 (2 late payments) • R01AI048071-22 • R01HL145411-05 • R01DA052845-04 • R01AI134245-07 • P51OD011133-26 • R01MH130193-03 • R01AI172539-02 (2 late payments) • P51OD011133-25 The total for the 18 subrecipient payments paid after 30 days was $127,273 and the total subrecipient payments in our sample of 40 was $323,770. Texas Biomed’s subrecipient expenditures totaled $2.6 million during the period, which represented 5.7% of Texas Biomed’s total research and development expenditures of $45.3 million. Identification as a repeat finding, if applicable This is a repeat finding – Finding 2022-001 and 2023-001. Recommendation We recommend Texas Biomed design and implement internal controls with the required precision to ensure subrecipients are paid within 30 days of the receipt of requests for reimbursement from the subrecipient. Views of responsible officials Management agrees with the finding and implemented corrective action in September 2024 to implement controls to ensure payments to subrecipients are made timely.

2024-001 – Material Weakness in Internal Control over Cash Management Identification of federal programs: United States Department of the Interior (DOI): #15.608 Fish and Aquatic Conservation - Aquatic Invasive Species: F21AC02420, F23AC01420, and F23AP01474 #15.685 National Fish Passage: F23AC02320 Criteria: Part 3 Compliance Supplement Non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: The Organization received advanced payments of grant funding and did not minimize the time elapsing between the transfer of funds and disbursement by the Organization. Advanced funding outstanding as of December 31, 2024 was as follows: #15.608: -F21AC02420 = $161,728 -F23AC01420 = $137,398 -F23AP01474 = $93,662 #15.685: -F23AC02320 = $54,037 Additionally, on the F23AC02320 annual financial report, the funding is improperly reported as liquidated cash disbursements and not cash on hand. Though it had been obligated, it had not yet been disbursed. Cause: The Organization’s written policies and procedures do not address all of the cash management requirements of Uniform Guidance. Previously, the Organization’s grants were operated on a reimbursement basis. At the end of the fiscal year under audit, due to the significant size and nature of the grants, and due to general economic uncertainty and internal risk assessments performed, the Organization determined that it was in their best interest to draw down grant funds in advance so that funding would be available for significant purchases during upcoming construction stages of the grants. Effect or potential effect: The Organization is not in compliance with the cash management requirements of the Uniform Guidance. Questioned Costs: None. Context: -#15.608: Three out of five grants had significant advanced funds outstanding at the end of the year, that were not subsequently disbursed soon after year end. -#15.685: One out of one grant had significant advanced funds outstanding at the end of the year, that were not subsequently disbursed soon after year end. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that the Organization reviews and revises their policies and procedures to ensure that they align with the cash management requirements of Uniform Guidance. We also recommend that as part of the Organization’s internal control structure over compliance with cash management requirements, to establish planning and monitoring procedures or checklists to ensure that timing is minimized between receipt from the U.S. Treasury or pass-through entity, and disbursement to the vendor. Additionally, we recommend that the Organization implements policy and procedures to ensure that earned interest is appropriately monitored and handled in accordance with the requirements of Uniform Guidance. Views of Responsible Officials: See Corrective Action Plan.

Criteria: Uniform Guidance requires payments to be based on reimbursement requests in accordance with 2 CFR 200.305. Condition: The Organization did not comply with the Uniform Guidance requirement to manage cash and requested payments in advance from the United States Department of Agriculture. Questioned Costs: $0 Cause: Inadequate oversight controls in the grant billing process resulted in duplicate Department of Agriculture reimbursement requests and funds received prior to issuing the related payments. Effect: The Organization was not in compliance with Uniform Guidance 2 CFR 200.305. Recommendation: We recommend the Organization monitors its budget and cash flows regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and in the summer of 2024, the Organization contracted with a third party accounting company to provide services.

Finding number 2024-002, material weakness in internal controls over compliance – cash management Federal Agency: U.S. Department of Justice Federal Program: Justice Reinvestment Initiative, ALN 16.827 Criteria: 2 CFR 200.303 states that the non-Federal entity is responsible for maintaining effective internal controls over cash management to comply with the terms and conditions of the Federal award. Under CFR 200.305(b), the timing of cash draws for cost reimbursement awards should be as close as administratively feasible to the actual disbursements of the expenditures. Condition: During the year ended December 31, 2024, the Organization’s federal draw down requests were not properly reconciled to actual cash needs. This also resulted in an instance where $121,533 was required to be returned to the awarding agency in June 2024. Cause: Inadequate procedures to monitor cash needs based on actual expenditures. Effect: The Organization temporarily held federal funds without immediate need and is not requesting funds based on actual expenditures incurred. Questioned Costs: None Recommendation: Management should improve the monitoring of actual expenditures to better align cash needs and draw down requests with actual expenditures incurred. Views of Responsible Officials: Management concurs with this finding. See Corrective Action Plan.

Criteria: Under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance, 2 CFR §200.305), non-federal entities must minimize the time between the receipt of federal funds and the disbursement of those funds for program purposes. Reimbursements must be used promptly to pay allowable costs incurred. Condition:Duringtheauditperiod,theCentersubmittedreimbursementrequestsfundsforallowableprogramexpenses andreceivedreimbursementinthesubsequentyear,butdidnotremitpaymenttovendorsinatimelymanner.3of the14 vendor invoices remained unpaid for extended periods despite the Center having received reimbursement for those costs. Cause: The delays in vendor payments were primarily due to weaknesses in internal cash management controls, including lack of reconciliation between reimbursement receipts and outstanding payables, and insufficient oversight of accounts payable processing. Effect: The Center was not in compliance with 2 CFR §200.305. Failure to promptly pay vendors after receiving reimbursement can also result in reputational risk, strained vendor relationships, and potential disallowance of costs by grantor agencies. Questioned Costs: None Recommendation: Management should establish procedures to ensure timely disbursement of funds upon receipt of reimbursements to vendors. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.

2024-001 Cash Management – WIC Reimbursement to Member Counties Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Number and Year: 202792; 2024 Pass-Through Agency: Minnesota Department of Health Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.305(b) states payment methods must minimize the time elapsing between the transfer of funds from the federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Condition: One of four subrecipient payments tested for compliance with federal cash management requirements was not paid timely to minimize the time elapsing between receipt of federal funds and disbursement to subrecipients. Questioned Costs: None. Context: Payment was made 126 days after receipt of the reimbursement request. The total amount reimbursed by the Minnesota Department of Health and paid to subrecipients is $1,087,575, consisting of 12 reimbursements. The sample of four reimbursements totaled $393,605. The payment made 126 days after receipt was for $89,935. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Partnership4Health is not in compliance with cash management requirements. Cause: Partnership4Health did not have backup procedures in place during an employee transition. Recommendation: We recommend Partnership4Health establish procedures to ensure cash management requirements are met. View of Responsible Official: Concur

Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S Department of Justice Federal Program: Congressionally Recommended Awards Assistance Listing Number: 16.753 Award Number: 15PBJA-23-GG-00920-BRND Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition The County received reimbursement for the total grant award amount prior to incurring expenditures. Criteria or specific requirement Compliance: Per 2 CFR section 200.305(b) For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Control: Per 2 CFR section 200.303(a), 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 the Federal award. These internal controls should comply 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). Context The County received $2.5 million on July 1, 2024, for the grant, as of that date the general ledger reported no expenditures. The County incurred expenditures of $274,235 in October, $62,247 in November, and $2,160,518 in December. Cause The County’s controls were not operating effectively to ensure reimbursement request were performed in accordance with federal requirements. Effect The County had to return funding of $1,367,790 in November, which was subsequently drawn in December when expenditures were incurred. Questioned Costs None noted. Recommendation We recommend that the County develop internal controls and procedures to ensure drawdowns are performed in a manner to minimize the time between drawing and disbursing federal funds Views of responsible officials and planned corrective actions Fiscal Clerk has been trained on proper drawdown of grant funds and accurate recording of expenditures.

Finding # 2024-003 Type: Immaterial noncompliance Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing: 11.441 Criteria/Requirement: In accordance with 2 CFR 200.305, organizations that receive more than $250,000 of federal funding per year should maintain those funds in an interest-bearing account. Interest earned in excess of $500 should be remitted back to the federal government. Cause: Funds are not maintained in an interest-bearing account. Effect: There are potential lost earnings and the Organization is not following federal guidelines. Recommendation: The Organization should change their primary operating account to an interest-bearing account. Management Response: Funds on hand will be moved to an interest-bearing account.

Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Relationship, Education, Advancement, and Development for Youth for Life Project Assistance Listing Number: 93.086 Assistance Listing Program Title: Healthy Marriage Promotion and Responsible Fatherhood Grants Award Period: September 30, 2023 – September 29, 2024 Award Period: September 30, 2024 – September 29, 2025 Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Teen Pregnancy Prevention Education Assistance Listing Number: 93.297 Assistance Listing Program Title: Adolescent Health Programs Award Period: July 1, 2023 – June 30, 2024 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Compliance and Internal Control over Compliance Criteria: Related to cash management, when entities are funded on a reimbursement basis, program costs must be incurred before the drawdown is requested according to CFR section 200.305. Nonprofits should document the basis, or calculation, used for each drawdown request to show that the amount requested matches the expenses incurred for the period. Additionally, CFR section 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control over the Federal awards that provides reasonable assurance that the Federal expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Drawdown requests should be reviewed and approved by appropriate personnel prior to submission by reviewing supporting documents to ensure amounts have been incurred.Condition: During audit testing of compliance and internal control over compliance, it was discovered funds were drawn down several times based on estimated bi-monthly expenses. Additionally, drawdown requests were not properly reviewed and approved by appropriate personnel. Cause: Due to staff turnover and timing constraints, the Organization utilized reasonable estimates rather than exact amounts for drawdown requests. Additionally, review and approval procedures related to drawdown requests were not being consistently performed. Effect: The estimated drawdown of funds could be different than actual expenditures incurred for the period, leading to costs being reimbursed prior to costs being incurred. As of December 31, 2024, all funds drawn were for expenses incurred prior to December 31, 2024. Additionally, the inconsistent application of internal controls could result in reimbursement of costs that were not incurred prior to drawdown. Questioned costs: No questioned costs were identified. Context: During audit testing of the Organization’s compliance and internal controls over compliance related to cash management, it was discovered the Organization at times utilized reasonable estimates rather than exact amounts for drawdown requests. Additionally, there was no review and approval of drawdown requests by appropriate personnel after February 2024, due to staff turnover. The audit team did not identify any questioned costs and concluded that the control failure was not indicative of fraud or illegal activities. Due to the compliance finding and lack of control, the audit team concluded the finding to be a significant deficiency in compliance and internal control over compliance. Recommendation: We recommend the Organization implement procedures to monitor drawdowns of funds so that funds are only requested when approved and documented reimbursable expenses have been incurred. Additionally, we recommend that management establish and enforce documented review and approval procedures of all drawdown requests. View of responsible officials: There is no disagreement with the audit finding.

Finding 2024-004 Lack of Internal Control over Cash Management Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: 21.027 Award Numbers: SLFRP4178/4850 Award Year: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that grant funds drawn down were used for grant expenditures in the applicable program. We compared the unearned revenue balances of the grant funds with the available cash balances at year end. The Village’s cash balances for all governmental funds amounted to $6,230,065 at December 31, 2024. The unearned revenues were $6,512,960 which resulted in a shortfall of $282,895. The CSLFRF program had an unearned revenue balance of $5,352,004 as of December 31, 2024. Cause: Lack of internal control over cash management. Effect: The Village requested and received advances for various federal programs to cover expenditures. Cash advances were used to fund other unrelated programs of the Village. Questioned Costs: $282,895, which is the shortfall between cash and cash equivalents and the unearned revenue balances. Repeat Finding: This is a repeat of Finding 2023-006, and since it is a repeat finding we believe this to be a systemic issue. Recommendation: We recommend that the Village monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs to ensure that unearned revenue balances do not exceed total cash and cash equivalents. Management’s Response: Management concurs with this finding. See corrective action plan.

Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S Department of Justice Federal Program: Congressionally Recommended Awards Assistance Listing Number: 16.753 Award Number: 15PBJA-23-GG-00920-BRND Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition The County received reimbursement for the total grant award amount prior to incurring expenditures. Criteria or specific requirement Compliance: Per 2 CFR section 200.305(b) For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Control: Per 2 CFR section 200.303(a), 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 the Federal award. These internal controls should comply 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). Context The County received $2.5 million on July 1, 2024, for the grant, as of that date the general ledger reported no expenditures. The County incurred expenditures of $274,235 in October, $62,247 in November, and $2,160,518 in December. Cause The County’s controls were not operating effectively to ensure reimbursement request were performed in accordance with federal requirements. Effect The County had to return funding of $1,367,790 in November, which was subsequently drawn in December when expenditures were incurred. Questioned Costs None noted. Recommendation We recommend that the County develop internal controls and procedures to ensure drawdowns are performed in a manner to minimize the time between drawing and disbursing federal funds Views of responsible officials and planned corrective actions Fiscal Clerk has been trained on proper drawdown of grant funds and accurate recording of expenditures.

Finding No. 2024-001 – Cash Management | Identification of the Program: | Program Name: Research and Development Cluster: Basic Scientific Research, Department of Defense Awarding Office, 12.431; NSF Technology, Innovation and Partnerships, National Science Foundation, 47.084 | Criteria or Specific Requirements (Including Statutory, Regulatory, or Other Citations): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” According to page 3-C-5 of the 2024 OMB Compliance Supplement, expenses must be incurred before submitting a reimbursement request (2 CFR § 200.305(b)(3)). | Condition: During our testing of 2024 reimbursement requests (totaling $536,272), we noted that there was no evidence of review and approval of the requests to indicate whether the reviewer determined that expenditures submitted for reimbursement had been incurred prior to the request for reimbursement. Management has indicated this review does, in fact, take place, however, there is no evidence (i.e., sign off) on the request to indicate that the review had occurred. | Section III— Federal Award Findings and Questioned Costs (continued) | Cause: Internal controls over the review and approval of the reimbursement requests were not effective. | Effect or Potential Effect: This could result in reimbursement for expenditures that have not been incurred and paid prior to reimbursement being requested. | Questioned Costs: None. | Context: As the sample size is small, we selected 10 cash disbursements for testing. There was no evidence of approval for all 10 reimbursement requests. | Identification as a Repeat Finding: N/A – This is a first year Uniform Guidance audit. | Recommendation: Management should strengthen its internal controls over cash management related to reimbursement requests by having the reviewer sign off on the reimbursement request to support that the review had occurred. | View of Responsible Officials: Management concurs with the findings and has developed a corrective action plan to address this finding.

Finding 2024-001: Lack of Internal Control over Financial Reporting Information on the Federal Program: Assistance Listing Number 11.405 - Cooperative Institute for Marine and Atmospheric Research. Award Number NA22NMF4050043 (MA 1797). Compliance Requirement: Reporting. Type of Finding: Material Noncompliance. Criteria: Uniform Guidance, 2 CFR § 200.305 Report Submission requires that a non-federal entity submit its Single Audit report, data collection form (SF-SAC), and reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after the receipt of the auditor's report or nine months after the end of the audit period. Condition: The auditee's fiscal year-end is December 31, 2024. Per 2 CFR § 200.512, the reporting package was due on September 30, 2025. The auditee did not submit the completed Single Audit package to the Federal Audit Clearinghouse until after the required due date. Context: A review of the auditee's internal records and the FAC website confirmed that the Single Audit reporting package was not submitted by the required deadline. The delay was primarily caused by the lack of timely reconciliation of the auditee's financial records, which postponed the auditor's ability to complete their fieldwork. Cause: Management had not established and maintained effective internal controls over reporting to ensure timely submission of audited financial statements to the Federal Audit Clearinghouse. Effect or Potential Effect: The late submission put the auditee in noncompliance with federal regulations. This hinders the oversight agency from getting timely information about the auditee’s financial and compliance status. A lack of internal controls over required compliance requirements could affect the Organization receiving future federal funding. Questioned Costs: None Repeat Finding: Repeat finding of 2024-001 Recommendation: We recommend that management timely submit annual audit report to the Federal Audit Clearinghouse. To do this, management should develop and implement a clear timeline with internal milestones for completing audit preparation and review. Management should also establish internal control procedures that assign specific responsibilities to staff to ensure that all federal reporting deadlines are met. Views of Responsible Official: Management of the Organization concurs with the audit finding and will immediately implement the auditors’ recommendations. Internal control procedures will be put into place to establish milestones and overseen by the Executive director.

Compliance Requirement Cash Management and Reporting Type of Finding Material Weakness in Internal Control over Compliance Material Noncompliance Program Port Security Grant Program ALN# 97.056 Federal Agency Department of Homeland Security – Direct Award Federal Award Year 2020, 2021, 2022 and 2023 Grant Number EMW-2022-PU-00022 – IJ#1, IJ#2, EMW-2023-PU-00164 – IJ#1, IJ#2, IJ#3, IJ#4 EMW-2024-PU-05541 – IJ#4 Questioned Costs None Criteria - Federal rules require grant recipients to request reimbursement from the federal government soon after paying expenses, rather than holding costs for long periods. They also require financial reports to be accurate, up to date, and complete. To meet these standards, timely reporting must be supported by timely reimbursement requests so that the reports truly reflect the District’s financial activity. Condition - Although the District submitted the required SF-425 Federal Financial Reports on a timely basis, it did not submit requests for reimbursement timely. Repeatedly, reimbursements were requested nine to twelve months after expenditures were incurred, creating cash flow inefficiencies and increasing risk of misreporting. The total value of these requests were $661,577 Cause - The District failed to establish and implement adequate procedures to ensure reimbursement requests were submitted in coordination with actual cash outflows. This control weakness reflects insufficient oversight of cash management practices and resulted in noncompliance with federal requirements for timely reimbursement.Effect - Delayed reimbursement requests reduce cash management efficiency and create potential inconsistencies between reporting and drawdown activity. Recommendation - The District must establish and enforce policies mandating that reimbursement requests be submitted promptly after vendor payments are made. The District must reconcile reimbursement activity with SF-425 reporting to ensure that expenditures are accurately, timely, and consistently reflected in financial reports submitted to FEMA, in compliance with 2 CFR 200.305 and 2 CFR 200.328

Condition and Context: The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, to follow the cash management standards set out at 2 CFR section 200.305. The County must have a complete set of written cash management policies, which conform to applicable Federal statutes and the cash management requirements identified in 2 CFR part 200. Cause: The County was unaware of the written cash management policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

Finding 2025-001: Cash Management (Material Weakness) Federal Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White Part C). [93.918] Federal Agency: U.S. Department of Health and Human Services (HHS) Criteria: Effective internal controls require an entity to have a financial management system that provides accurate, current, and complete disclosure of the financial results of a federally assisted project (2 CFR § 200.302). Drawdown requests must be based on actual incurred expenditures and be properly reviewed for accuracy before submission to minimize the time between draw and disbursement (2 CFR § 200.305). Additionally, the entity must maintain records that adequately identify the source and application of funds for all federally assisted activities (2 CFR § 200.333). Condition: During our audit of the financial management system and cash management practices for the Ryan White Federal Program, we identified the following deficiencies: Transposed Drawdown Amount: A drawdown request submitted to the PMS system for the Ryan White Program had the requested amount transposed with the amount of another federal program. This resulted in an over-request of a material amount on the Ryan White Program. Duplicate Invoice Reimbursement: An invoice was requested and received for reimbursement on a prior drawdown and was subsequently included again in a draw after year-end, resulting in a duplicate reimbursement. Incomplete Expenditure Tracking: The entity did not have a complete system for tracking all expenditures eligible for reimbursement. The drawdown process was limited to cash disbursement and payroll transactions and excluded expenditures incurred and recorded by journal entries. This resulted in the entity having unreimbursed expenditures that could have offset the over-requests noted above. Questioned Costs: $252,567 The questioned costs consist of the material amount over-requested in the transposed drawdown and the duplicate reimbursement of the previously paid invoice. A detailed breakdown is as follows: Over-requested amount due to transposed data: $150,516 Duplicate reimbursement for invoice submitted twice: $102,051 Cause: The organization's internal controls over the cash management and drawdown request process were inadequate. Specifically, there was a lack of a formal review and approval process to verify the accuracy and completeness of drawdown requests before they were submitted. Effect: The deficiencies in internal control led to material noncompliance with federal regulations related to financial management and cash management. This resulted in the entity holding federal funds in excess of immediate needs, which is a violation of the terms and conditions of the federal award. The inadequate financial management system also prevented the entity from accurately tracking and requesting all eligible expenditures, which could have helped offset the over-draws. Context: This is a systemic finding. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: The entity should implement robust internal controls to ensure all drawdown requests are reviewed and approved by a second person with authority. A reconciliation of expenditures to the general ledger should be performed before each drawdown to ensure all eligible costs are included and that no duplicate requests are made. The entity’s cash management policies and procedures should be updated to address these deficiencies and ensure compliance with federal requirements. Management Response: The organization acknowledges and we are committed to remediation. To correct the deficiency, we are implementing a plan focused on establishing a review and approval process for all drawdown requests and revising our policies to ensure that all eligible incurred expenditures are properly captured and reconciled, thereby assuring strict compliance with federal cash management regulations and preventing federal funds from exceeding our immediate needs.

Condition and Context: The County does not have a complete set of written cash management policies and procedures required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the cash management standards set out at 2 CFR section 200.305. They must have a complete set of written cash management policies, which conform to applicable Federal statutes and the cash management requirements identified in 2 CFR part 200. Cause: The County was unaware of the written cash management policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

Criteria or specific requirement: 2 CFR section 200.305(b)(1) requires that an entity implement procedures to ensure that the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient be minimized. 2 CFR section 200.305 (b)(3) states the pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the request is believed to be improper. Condition: 5 out of 18 total billings sampled were not paid timely. Questioned costs: None. Context: During our testing of subrecipient payments, 5 out of the 18 billings sampled were not paid within 30 calendar days to the subrecipient after the billing was submitted for payment. Cause: Policies and procedures were not in place to ensure timely payments of subrecipient billings. Effect: Subrecipients received payments a significant amount of time after expenditures have been incurred. Repeat Finding: Yes. Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Views of responsible officials: There is no disagreement with the audit finding.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-010: Cash Management - Inadequate Policies for Drawdowns, Program Income, and Reconciliations (Material Weakness) Federal Program : Grants for Transportation of Veterans in Highly Rural Areas Assistance Listing Number : 64.035 Criteria: 2 CFR 200.305 requires documented procedures for cash management, including drawdowns, program income usage, and reconciliation processes. Condition: The Center does not have comprehensive written policies governing drawdowns, program income application, and required reconciliations. Cause: Noncompliance with Federal cash management and program income requirements may result in questioned costs or delayed reimbursements. Effect: Late submission constitutes noncompliance with federal regulations and may delay future federal funding or result in additional oversight. Recommendation: Management should develop and adopt formal written policies detailing drawdown procedures, program income usage, and reconciliation requirements. Repeat Finding: This is not a repeat finding.

Criteria – Uniform Guidance (2 CFR §200.305) requires that non-federal entities establish and maintain written procedures to minimize the time elapsing between the transfer of federal funds from the U.S. Treasury and the disbursement of those funds for allowable program expenditures. In addition, entities must maintain adequate documentation to support all drawdowns and ensure that amounts requested are based on actual, allowable costs incurred. Condition and Description – During our audit, we identified deficiencies in the Organization’s compliance with federal cash management requirements and internal controls over reporting of federal expenditures. Specifically, documentation supporting certain drawdowns of federal funds was not consistently maintained. However, the total drawdowns did not exceed eligible expenses. In addition, we noted timing differences between when expenses were recognized in the financial statements and when related drawdowns were requested and reported to the federal government. These conditions create the risk that federal funds may not be drawn down in alignment with actual expenditures, resulting in temporary over- or under-drawdowns, increasing the likelihood of noncompliance with Uniform Guidance requirements and misstatements of federal program expenditures. Questioned Costs – Unknown. Cause/Effect – Drawdowns were not consistently reconciled to underlying expenses, and supporting documentation was incomplete. Timing differences between expenditures and drawdowns were not addressed, creating the risk of temporary over- or under-drawdowns and noncompliance with federal cash management requirements.

Finding 2024-002: Cash Management Requirements U.S Department of Health and Human Services – Pass-through Office of Refugee Resettlement – Unaccompanied Children ALN 93.676 Cash Management Statement of Condition: During the audit of KidsPeace it was observed that the organization did not minimize the time elapsing between the transfer of funds from the Federal agency to the disbursement of these funds. Funds were drawn down in advance of actual disbursement needs resulting in excess cash balances. Questioned Costs: None. Criteria: According to 2CFR 200.305(b), non- Federal entities must minimize the time elapsing between the transfer of funds from the federal agency and the disbursement of funds by the non- Federal entity. Advance payments must be limited to the minimum amounts needed and timed in accordance with the actual immediate cash requirements of the entity in carrying out the purpose of the program. Cause: The organization lacked adequate procedures to ensure that funds were drawn down only as needed for immediate disbursement. Additionally, there was insufficient oversight of cash management practices. Effect of the Condition: The cash on hand by year end was approximately $1.37 million which is in excess of the immediate needs of the program Repeat Finding: This is a repeat finding for 2023-001. Recommendation: We recommend that the Organization implements further procedures to ensure the drawdown amounts reflect actual expenditures incurred. Views of Responsible Officials: Management agrees with the findings. See corrective action plan.

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 CFR § 200.302(b)(6) states the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Additionally, for Federal awards, the Uniform Guidance requires a written policy for the procurement requirements outlined in 2 CFR § 200.318(c)(1), 2 CFR § 200.318(c)(2), and 2 CFR § 200.320(B) 2 CFR 200.302(b)(7) requires written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of this part and the terms and conditions of the Federal award. 2 CFR 200.430 states that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR 200.431 requires established written leave policies if the entity intends to pay fringe benefits. 2 CFR 200.464(a)(2) requires reimbursement of relocation costs to employees be in accordance with an established written policy must be consistently followed by the employer. 2 CFR 200.475 requires reimbursement and/or charges to be consistent with those normally allowed in like circumstances in the non-Federal entity's non-federally-funded activities and in accordance with non-Federal entity's written travel reimbursement policies. The General Health District did not have written policies as required by Uniform Guidance. The failure to implement written policies as required by Uniform Guidance could result in noncompliance with the District’s federal programs. The General Health District should adopt written policies in accordance with the Uniform Guidance.

Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2024-001: Cash Management (Material Weakness) Federal Programs: ALN 19.019 Criteria: According to 2 CFR 200.305, recipients must draw Federal funds only in amounts necessary to meet immediate cash needs for program expenditures. Funds should be disbursed as soon as possible, generally within three business days of receipt. Condition: During our testing of cash management compliance, we noted that ICMEC drew down a total of $233,494 on Federal funds in advance of need. The remaining funds were used for other ICMEC programmatic work. Cause: ICMEC did not have adequate procedures to align Federal drawdown requests with immediate program disbursement requirements. Drawdowns were based on budgeted monthly cash needs rather than actual expenditures. Effect or Potential Effect: Drawing funds in advance of need results in excess Federal cash being held by ICMEC, which is not permitted under Federal regulations. This increases the risk of misuse of Federal funds and may result in ICMEC owing interest to the Federal Government. Questioned Costs: $233,494 Context: Our audit procedures consisted of testwork completed on individual cash receipts and draw downs requests and evaluating the refundable advance analysis prepared by ICMEC as of December 31, 2024. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend ICMEC establish and implement procedures to ensure drawdown requests are limited to actual, immediate cash needs, with monitoring to confirm that Federal funds are disbursed within three business days of receipt.

Cash Management Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 001 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.305 Federal Payment (b)(3) Payments for recipients and subrecipients other than States requires that, “Reimbursement is preferred when the requirements in paragraph (b) cannot be met, when the Federal agency or pass-through entity sets a specific condition per Section 200.208, when requested by the recipient or subrecipient, when a Federal award is for construction, or when a significant portion of the construction project is accomplished through private market financing or Federal loans and the Federal award constitutes a minor portion of the project. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.” CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its cash management requirements in accordance with federal regulations. CAUSE Based on discussions with management, a portion of the late payments resulted from the SAO’s Program Managers being unable to provide sufficient documentation demonstrating that the delays were due to late invoice submissions by subrecipients. As a result, the Auditor could not verify whether the non-compliance was attributable to subrecipient actions. The remaining delays were due to weaknesses in the payment processing system, which relied heavily on email communications between involved parties. These emails, initiated by the Accounts Payable Processor, were not acted upon in a timely manner, resulting in payments being processed well over the thirty (30) days after initial submission. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s billing or payment request is a violation of federal regulations. This could impact the subrecipient’s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. CONTEXT During our test of 29 subrecipients’ expenditures, we noted 17 instances where payments to the subrecipients’ were not made within 30 days after receipt of the subrecipient’s payment request. The payments were submitted late, ranging from 2 to 313 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that SAO develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients billing or payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 38.

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.

Cash Management Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 001 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.305 Federal Payment (b)(3) Payments for recipients and subrecipients other than States requires that, “Reimbursement is preferred when the requirements in paragraph (b) cannot be met, when the Federal agency or pass-through entity sets a specific condition per Section 200.208, when requested by the recipient or subrecipient, when a Federal award is for construction, or when a significant portion of the construction project is accomplished through private market financing or Federal loans and the Federal award constitutes a minor portion of the project. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.” CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its cash management requirements in accordance with federal regulations. CAUSE Based on discussions with management, a portion of the late payments resulted from the SAO’s Program Managers being unable to provide sufficient documentation demonstrating that the delays were due to late invoice submissions by subrecipients. As a result, the Auditor could not verify whether the non-compliance was attributable to subrecipient actions. The remaining delays were due to weaknesses in the payment processing system, which relied heavily on email communications between involved parties. These emails, initiated by the Accounts Payable Processor, were not acted upon in a timely manner, resulting in payments being processed well over the thirty (30) days after initial submission. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s billing or payment request is a violation of federal regulations. This could impact the subrecipient’s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. CONTEXT During our test of 29 subrecipients’ expenditures, we noted 17 instances where payments to the subrecipients’ were not made within 30 days after receipt of the subrecipient’s payment request. The payments were submitted late, ranging from 2 to 313 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that SAO develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients billing or payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 38.

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025

2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.