Findings Citing § 200.326

2022-001 Procurement, Suspension and Debarment ALN Number Name of Federal Program 10.760 Water and Waste Disposal Systems Identification as a Repeat Finding: Repeat of Finding 2021-001 Finding: The Association did not have a written procurement policy that complies with the procurement standards established in 2 CFR sections 200.318 through 200.326 in place for the full compliance year. Criteria: Non-Federal entities other than States must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR 200. Condition and context: Sallal Water Association adopted a procurement policy for goods and service providers that complies with federal procurement standards in December 2022. As such, it was non-compliant with the federal standards for 11 months of the compliance year. Sample size and population: Sampling was not applicable to this finding. Effect: The result of the finding is that Sallal Water Association is not in compliance with federal procurement standards for 11 months of the compliance year. Recommendation: None as the Association adopted a written procurement policy in December 2022. Question Costs: None Management Response and Corrective Action Plan: See Corrective Action Plan Contact Person: Kristina Parker, Director of Finance and Operations

2022-005 Finding Federal Program Coronavirus State and Local Fiscal Recovery Funds (21.027) Federal Award Number and Year ? SLFRP2882, 2021 Procurement, Suspension, and Debarment Material Weakness Criteria Uniform Guidance requires all non-federal entities, other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Non-federal entities are also prohibited from entering into a covered transaction equal to or exceeding $25,000 with a vendor who has been suspended or disbarred from receiving federal funds. Condition We noted during testing procurement, suspension, and debarment that the County doesn?t have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Cause Lack of oversight by management. Questioned Costs None Context Uniform Guidance states ?Review the non-federal entity?s procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096)?. During this review, we noted that during our testing of procurement, suspension, and debarment that the County doesn?t have a procurement policy that follows Uniform Guidance. We also noted during testing for suspension and debarment that 3 of our 4 vendors tested were not reviewed to ensure they were not suspended or disbarred from federal funds. Effect The County has an increased risk of not being compliance with federal procurement requirements and increased risk of entering into a covered transaction with a vendor who is suspended or disbarred from federal funds. Repeat Finding Yes ? see 2021-005 Recommendation The County should update their Procurement Policy to include suspension and debarment verbiage. Views of Responsible Officials See Corrective Action Plan.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Program Information Assistance Listing # 93.137 Community Programs to Improve Minority Health Grant Program 2022-002 Policies and Procedures Material Weakness Criteria: The Code of Federal Regulations (CFR) Section 200.318 - 200.326 require written policies concerning methods of procurement for goods and services. Condition: The Organization did not have a written procurement policy that included all of the required elements during 2022. Cause: The Organization is smaller and while general procedures for the procurement of goods and services have been established, they were not written and did not meet all of the requirements of the CFR. Effect: The Organization is not in compliance with Section 200.318 - 200.326 of the Code of Federal Regulations. Auditor?s Recommendation: We recommend that the Organization adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and adopted a ?Fiscal Policies and Procedures Manual? on October 1, 2022.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Program Information Assistance Listing # 93.137 Community Programs to Improve Minority Health Grant Program 2022-002 Policies and Procedures Material Weakness Criteria: The Code of Federal Regulations (CFR) Section 200.318 - 200.326 require written policies concerning methods of procurement for goods and services. Condition: The Organization did not have a written procurement policy that included all of the required elements during 2022. Cause: The Organization is smaller and while general procedures for the procurement of goods and services have been established, they were not written and did not meet all of the requirements of the CFR. Effect: The Organization is not in compliance with Section 200.318 - 200.326 of the Code of Federal Regulations. Auditor?s Recommendation: We recommend that the Organization adopt a formal written procurement policy in the format and with the elements required by 2 CFR Sections 200.318 to 200.326. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and adopted a ?Fiscal Policies and Procedures Manual? on October 1, 2022.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.

2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.

Federal agency: U.S. Department of Treasury Federal program name: COVID-19 State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3395, 2022 Award Period: 6/13/2021 ? 12/31/2026 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: In our testing for the State and Local Fiscal Recovery Funds procurements, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 21.027 - $222,175.04 Context: Out of five procurement which were tested, we noted one for which the City did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Effect: The City is not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Recommendation: We recommend the City reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: The County did not have proper procurement documentation available for the contracts tested in the audit. Questioned costs: None Context: Five of the five contracts tested did not have the proper supporting documentation to demonstrate that procurement procedures were followed in accordance with the County?s procurement policy. Cause: The contracts were in process before the funding was assigned to the projects and there was turnover at the County. Effect: Failure to document the procurement process exposes the County to the risk that the County?s procurement policy was not followed before the contracts were awarded. Repeat Finding: No. Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: The County did not have proper procurement documentation available for the contracts tested in the audit. Questioned costs: None Context: Five of the five contracts tested did not have the proper supporting documentation to demonstrate that procurement procedures were followed in accordance with the County?s procurement policy. Cause: The contracts were in process before the funding was assigned to the projects and there was turnover at the County. Effect: Failure to document the procurement process exposes the County to the risk that the County?s procurement policy was not followed before the contracts were awarded. Repeat Finding: No. Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. This procurement process must be documented with proper supporting documentation. Condition: The County did not have proper procurement documentation available for the contracts tested in the audit. Questioned costs: None Context: Five of the five contracts tested did not have the proper supporting documentation to demonstrate that procurement procedures were followed in accordance with the County?s procurement policy. Cause: The contracts were in process before the funding was assigned to the projects and there was turnover at the County. Effect: Failure to document the procurement process exposes the County to the risk that the County?s procurement policy was not followed before the contracts were awarded. Repeat Finding: No. Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

2022-003 FINDING Federal Program Coronavirus State and Local Fiscal Recovery Funds (AL 21.027) Procurement, Suspension, Debarment Criteria Organizations must follow federal procurement standards as set out in 2 CFR section 200.318 through 200.326. For purchases that exceed $10,000, small purchase procedures must be followed including obtaining multiple quotes. Condition For an equipment purchase contract that exceeded $10,000, the County failed to obtain multiple quotes. Questioned Costs None Context The County was not in compliance with federal procurement standards. Cause Oversight by County staff. Effect County failed to obtain multiple quotes and was not in compliance with federal procurement requirements. Repeat Finding No Recommendation The County should implement procedures to ensure that federal procurement standards are followed for federal grant purchases. Views of Responsible Officials and Planned Corrective Actions The County agrees with the recommendation and will review its procedures.

2022-004 - PROCUREMENT Criteria: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own documented procedures for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Condition: As of December 31, 2022, the Township did not have their own written procurement policy to properly implement all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: The Township was unaware of the requirement. Effect: The Charter Township of Portage is not in compliance with the procurement policy requirements identified in 2 CFR section 200.318 through 200.326 which could jeopardize federal funding. Questioned Costs: This finding does not result in questioned costs. Recommendation: The Charter Township of Portage should create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200.326. View of Responsible Officials: Management is in agreement and has drafted a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200.326 that has been approved by the Township board on June 12, 2023. The policy has been submitted to the Township attorney for review, and will be finalized pending any modifications or recommendations by their attorney.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes; 2021-001 Program Name/Assistance Listing Title: MBDA Business Center Assistance Listing Number: 11.805 Federal Agency: US Department of Commerce Federal Award Numbers: MB20OBD8050207, MB21OBD8050182 Pass-Through Agency: N/A Questioned Costs: $200,052 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ?200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION Adequate internal controls over the organization?s procurement procedures to ensure compliance with federal regulations and guidelines were not in place. In addition, the organization did not verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Staff were not aware of the procurement requirements contained within 2 CFR part 200, and, therefore, no internal controls had been designed or implemented to avoid non-compliance until June 2022 when the organization underwent its first single audit. A procurement policy was created and implemented in October 2022, well after the contracts were in place for the purchases identified in the finding. EFFECT The organization was not in compliance with federal guidelines regarding procurement. CONTEXT During our review of purchases, we noted the following: ? The Organization did not establish written procurement standards until October 2022. The procurements standards did not establish suspension and debarment checks for vendors. ? Small purchase procedures were not followed for seven purchases that exceeded the micropurchase threshold ($10,000) but were less than the simplified acquisition threshold ($250,000). These purchases were contracted before the Organization was aware of the deficiency, which was first identified during the previous single audit in summer 2022. ? The Organization did not verify four vendors were not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The Organization should establish written procurement standards address suspension and debarment requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes; 2021-001 Program Name/Assistance Listing Title: MBDA Business Center Assistance Listing Number: 11.805 Federal Agency: US Department of Commerce Federal Award Numbers: MB20OBD8050207, MB21OBD8050182 Pass-Through Agency: N/A Questioned Costs: $200,052 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ?200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION Adequate internal controls over the organization?s procurement procedures to ensure compliance with federal regulations and guidelines were not in place. In addition, the organization did not verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Staff were not aware of the procurement requirements contained within 2 CFR part 200, and, therefore, no internal controls had been designed or implemented to avoid non-compliance until June 2022 when the organization underwent its first single audit. A procurement policy was created and implemented in October 2022, well after the contracts were in place for the purchases identified in the finding. EFFECT The organization was not in compliance with federal guidelines regarding procurement. CONTEXT During our review of purchases, we noted the following: ? The Organization did not establish written procurement standards until October 2022. The procurements standards did not establish suspension and debarment checks for vendors. ? Small purchase procedures were not followed for seven purchases that exceeded the micropurchase threshold ($10,000) but were less than the simplified acquisition threshold ($250,000). These purchases were contracted before the Organization was aware of the deficiency, which was first identified during the previous single audit in summer 2022. ? The Organization did not verify four vendors were not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The Organization should establish written procurement standards address suspension and debarment requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

2022-004 Department of Environmental Protection Agency, Passed through North Dakota Department of Environmental Quality Federal Financial Assistance Listing/CFDA Number 66.458 Clean Water State Revolving Fund Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria ? Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition ? During the course of our engagement, it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect ? A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with of procurement, suspension, and debarment. Questioned Costs ? None reported Context/Sampling ? Overall Procurement Policy Repeat Finding from Prior Year(s) ? No Recommendation ? We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials ? There is no disagreement with the finding.

Finding # 2022-002 Type: Immaterial Noncompliance over Procurement Assistance Listing Number: U.S. Department of Agriculture - Rural Development 10.755 Rural Innovation Stronger Economy U.S. Department of the Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria/Requirement: The Organization should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 including documentation to justify when a competitive process was not used. The Organization?s procurement policies also should be expanded to incorporate the provisions of the standards referenced. Condition: The procurement process was not properly documented and executed. For two out of two samples selected for testing, there was no documentation of the procurement process performed or reviewed. Cause: The Organization?s procurement policy does not meet the required federal standards, and application of the policy was not consistently applied. Effect: The Organization?s contracts could be from disbarred or disallowed vendors. Questioned Costs: None. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Management Response: Management will review the federal procurement guidelines and update its policies and procedures to be consistent with federal requirements.

Finding # 2022-002 Type: Immaterial Noncompliance over Procurement Assistance Listing Number: U.S. Department of Agriculture - Rural Development 10.755 Rural Innovation Stronger Economy U.S. Department of the Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria/Requirement: The Organization should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 including documentation to justify when a competitive process was not used. The Organization?s procurement policies also should be expanded to incorporate the provisions of the standards referenced. Condition: The procurement process was not properly documented and executed. For two out of two samples selected for testing, there was no documentation of the procurement process performed or reviewed. Cause: The Organization?s procurement policy does not meet the required federal standards, and application of the policy was not consistently applied. Effect: The Organization?s contracts could be from disbarred or disallowed vendors. Questioned Costs: None. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Management Response: Management will review the federal procurement guidelines and update its policies and procedures to be consistent with federal requirements.

Finding # 2022-002 Type: Immaterial Noncompliance over Procurement Assistance Listing Number: U.S. Department of Agriculture - Rural Development 10.755 Rural Innovation Stronger Economy U.S. Department of the Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria/Requirement: The Organization should follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 including documentation to justify when a competitive process was not used. The Organization?s procurement policies also should be expanded to incorporate the provisions of the standards referenced. Condition: The procurement process was not properly documented and executed. For two out of two samples selected for testing, there was no documentation of the procurement process performed or reviewed. Cause: The Organization?s procurement policy does not meet the required federal standards, and application of the policy was not consistently applied. Effect: The Organization?s contracts could be from disbarred or disallowed vendors. Questioned Costs: None. Recommendation: The Organization's procurement policy must have documented procurement procedures, consistent with state, local, and tribal laws and regulations for the acquisition of property or services required under a federal award or subaward. The Organization should maintain records sufficient to detail the history of procurement. Management Response: Management will review the federal procurement guidelines and update its policies and procedures to be consistent with federal requirements.

2022-001 ? Procurement Suspension & Debarment Program: AL# 97.024 ? Emergency Food and Shelter National Board Program Sponsor Award Number: Phase 39; ARPAR Sponsor Agency: U.S. Department of Homeland Security Criteria: Non-federal entities that are operating federal programs must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. This includes utilizing appropriate procurement methods and following requirements for each method selected. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Citation: 2 CFR section 200.320(b) Condition: The Organization did not obtain price or rate quotes from an adequate number of qualified sources. Cause: Although the Organization?s procurement policies and procedures are updated to comply with the Uniform Guidance, they were not consistently followed. Effect: Failure to obtain price or quotes from an adequate number of qualified sources may result in ineffective use of government funds. Questioned Costs: None. Context: During our testing of the Organization?s procurement requirements, we noted a lack of documentation supporting the Organization?s review of an adequate number of qualified sources before the procurement decision was made. Repeat Finding: No Recommendation: We recommend that the Organization implement monitoring procedures to ensure internally established procurement policies are followed. Documentation should include the rationale for the method of procurement used, the basis for contractor selection, and the basis for the contract price. Views of Responsible Officials: See Corrective Action Plan.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Moving to Work Demonstration Program Assistance Listing Number: 14.881 Federal Award Identification Number and Year: OR02VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Home Forward must do the following: ? As a condition to executing payment for a contract subject to wage rate requirements, require the contractor to submit to them weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: Home Forward provided payment for a contractor agreement that included wage rate requirements. Questioned costs: Unable to determine. Context: Exceptions noted in 1 out of 5 contracts tested for wage rate requirements: ? Payment was made on a contract for which certified payrolls were required but not submitted. The sample was statistically valid. Cause: Home Forward did not follow the established procedures for payment of construction contracts subject to wage rate requirements. Effect: Home Forward is not in compliance with wage rate requirements. Repeat Finding: No. Recommendation: We recommend Home Forward review their process and internal controls over contracts subject to wage rate requirements to ensure compliance with HUD requirements. Views of responsible officials: There is no disagreement with the audit finding.

Finding 2022-001: Reportable Finding Considered a Significant Deficiency ? Procurement Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Agricultural Worker Pandemic Relief and Protection Program Award Number: AM22FFWDC0002-00 Grant Years: 2022 Criteria: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Section 200.318 General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 200.320 Methods of procurement to be followed, states that for acquisitions exceeding the simplified acquisition threshold, the nonfederal entity must use one of the following procurement methods: (a) the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); (b) the competitive proposals method under the conditions specified in 2 CFR section 200.320(b)(2); or (c) the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c). Condition: During our 2022 audit, we noted three consultant contractors which were charged to the Federal program under the competitive proposals method but did not comply with the criteria in 2 CFR section 200.320(b) and one noncompetitive proposals method but did not comply with the criteria in 2 CFR section 200.320(c). We noted that the Foundation did not have records sufficient to detail the history and the rationale of the method of procurement at the time the contracts were executed. Cause: The Foundation did not document the history or the justification for the method of procurement selected for various consultants charged to the Federal program at the time the contracts were executed. Effect: The Foundation may have inadvertently selected noncompetitive proposals by not following the requirements noted in section 200.320 Methods of procurement to be followed, and thereby failing to full and open competition as required by the regulations. Context: There were four consultants during the audit period for which 2 CFR section 200.320 applied. Questioned Costs: There are no questioned costs associated with this finding. Repeat Finding: This is not a repeat finding. Recommendation: The Foundation should adopt and enforce a procurement policy that follows the procurement standards set out at 2 CFR sections 200.318 through 200.326. We also recommend that documentation is maintained to substantiate adherence to this policy and ensure that all instances are adequately documented according to the regulations, including for contacts already in place.

2022-003 Procurement Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 22MN101S2514 - 202 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 22MN101S2514, 22MN127Q7503, 22MN101S2520 Award Period: January 1, 2022 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations ? 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/Context: For 1 of 2 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Questioned costs: $111,837 was paid to the vendor during 2022. Cause: County federal procurement policies were not followed. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could result in the loss of federal funds to the County. Repeat Finding: No Recommendation: We recommend County management establish a system of internal controls to ensure compliance with federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

2022-003 Procurement Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 22MN101S2514 - 202 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 22MN101S2514, 22MN127Q7503, 22MN101S2520 Award Period: January 1, 2022 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations ? 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/Context: For 1 of 2 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Questioned costs: $111,837 was paid to the vendor during 2022. Cause: County federal procurement policies were not followed. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could result in the loss of federal funds to the County. Repeat Finding: No Recommendation: We recommend County management establish a system of internal controls to ensure compliance with federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

2022-003 Procurement Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 22MN101S2514 - 202 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 22MN101S2514, 22MN127Q7503, 22MN101S2520 Award Period: January 1, 2022 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations ? 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/Context: For 1 of 2 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Questioned costs: $111,837 was paid to the vendor during 2022. Cause: County federal procurement policies were not followed. Effect: The failure to establish an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could result in the loss of federal funds to the County. Repeat Finding: No Recommendation: We recommend County management establish a system of internal controls to ensure compliance with federal procurement requirements. Views of responsible officials: There is no disagreement with the audit finding.

Finding number: 2022-001 Repeat finding: No Assistance Listing Number: 93.224 / 93.527 Assistance Listing Title: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Description: Procurement and Suspension and Debarment Criteria: Under 2 CFR ?215.43 the Organization is required to implement certain procurement policies that adhere to the minimum Federal requirements as outlined in 2 CFR ?215.44. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The procurement method the Organization used did not meet procurement standards as set forth in 2 CFR sections 200.320. A sole source procurement method was used when the vendor did not meet the sole source definition. Cause: The Organization was not fully aware of the federal procurement compliance requirements. Effect: The Organization was not in compliance with their own policies or with federal regulations. Recommendation: The Organization should ensure procurement policies are being followed for all procurement levels. The Organozation should also seek out additonal training for procurment to ensure federal rules and requirements are being met. View of responsible officials: Management acknowledges this condition related to lack of adequate controls over procurement and is creating controls that will assure compliance with requirements.

Finding number: 2022-001 Repeat finding: No Assistance Listing Number: 93.224 / 93.527 Assistance Listing Title: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Description: Procurement and Suspension and Debarment Criteria: Under 2 CFR ?215.43 the Organization is required to implement certain procurement policies that adhere to the minimum Federal requirements as outlined in 2 CFR ?215.44. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The procurement method the Organization used did not meet procurement standards as set forth in 2 CFR sections 200.320. A sole source procurement method was used when the vendor did not meet the sole source definition. Cause: The Organization was not fully aware of the federal procurement compliance requirements. Effect: The Organization was not in compliance with their own policies or with federal regulations. Recommendation: The Organization should ensure procurement policies are being followed for all procurement levels. The Organozation should also seek out additonal training for procurment to ensure federal rules and requirements are being met. View of responsible officials: Management acknowledges this condition related to lack of adequate controls over procurement and is creating controls that will assure compliance with requirements.

Finding number: 2022-001 Repeat finding: No Assistance Listing Number: 93.224 / 93.527 Assistance Listing Title: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Description: Procurement and Suspension and Debarment Criteria: Under 2 CFR ?215.43 the Organization is required to implement certain procurement policies that adhere to the minimum Federal requirements as outlined in 2 CFR ?215.44. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The procurement method the Organization used did not meet procurement standards as set forth in 2 CFR sections 200.320. A sole source procurement method was used when the vendor did not meet the sole source definition. Cause: The Organization was not fully aware of the federal procurement compliance requirements. Effect: The Organization was not in compliance with their own policies or with federal regulations. Recommendation: The Organization should ensure procurement policies are being followed for all procurement levels. The Organozation should also seek out additonal training for procurment to ensure federal rules and requirements are being met. View of responsible officials: Management acknowledges this condition related to lack of adequate controls over procurement and is creating controls that will assure compliance with requirements.

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.

Condition: The Organization does not have a documented procurement policy that conforms to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Context: During the year, the Organization made a purchase of property that was greater than the Simple Acquisition Threshold of $250,000. As part of the audit procedures, we requested the Organization’s documented procurement policy. The Organization did not have a documented procurement policy. Prior to making purchases in excess of the simplified acquisition threshold, the Organization performed a price analysis in a manner consistent with 2 CFR Part 200. Cause: The Organization was not aware that a documented procurement policy was required. Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Effect: Without documented procurement policies, the Organization could procure assets in a manner that is not consistent with 2 CFR Part 200. Recommendation: We recommend that the Organization familiarize themselves with the requirements of 2 CFR sections 200.318 through 200.326 and develop a documented procurement policy that conforms to applicable federal statutes and procurement requirements. Management’s Response: Management agrees.

Department of the Treasury, Passed through North Dakota Office of Management and Budget Federal Financial Assistance Listing 21.027 COVID‐19 – Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension, and debarment it was identified that the City did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of compliant policies increases the overall risk of non‐compliance. Questioned Costs – None reported. Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2021‐003. Recommendation – We recommend that management establish a written policy that is in compliance with all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.

Federal Program: 594 Environmental Infrastructure Assistance Program (AL 12.U01): Procurement, Suspension, and Debarment Criteria: Per Uniform Guidance, “Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR section 200.318 through 200.326. They must use their own documented procurement procedures, which reflect appliable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Furthermore, “Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: During testing, we noted that the City does not have a procurement policy in place that follows Uniform Guidance. Also, we noted that the City entered into two covered transactions with vendors who were not reviewed for suspension and debarment before entering into these transactions. Questioned Costs: None. Context: The City does not have a procurement policy that follows Uniform Guidance. Also, we tested two vendors who were not reviewed for suspension and debarment from a population of two. Cause: Management Oversight. Effect: The City is not in compliance with Uniform Guidance. Also, there is an increased risk of the City entering into a covered transaction with an entity that is suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: The City should implement a written procurement policy that follows Uniform Guidance. Furthermore, vendors should be reviewed for suspension and debarment before entering into a covered transaction. View of Responsible Officials: The City agrees with the recommendation.

2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.

2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.

2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.

2022-001 – Procurement and Suspension and Debarment Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Program: Rural Communities Opioid Response – Planning/Rural Health Outreach and Rural Network Development Program (AL# 93.912); U.S. Department of Health and Human Services; Direct award; all grant numbers. Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization's procurement policies were not complete and the Organization did not follow the federal procurement standards which provides specific guidance including process and documentation requirements necessary to be in compliance as required by the 2 CFR sections 200.318 through 200.326. Cause: The Organization’s procurement policies do not include the federal procurement requirements noted at 2 CFR section 200.318 through 200.326. Additionally, the Organization did not maintain the required procurement documentation, provide for full and open competition, or provide support for limitation of such competition. Effect: Future procurement arrangements may not meet the federal guidelines necessary for projects funded by federal sources. The Organization may have to pay back funds received for a project where federal funds were used for the procurement of products or services, but the required federal process was not met. Questioned Costs: No costs were questioned as a result of this finding. Recommendation: The Organization should update their procurement policy to include all requirements as noted in 2 CFR sections 200.318-200.326 and ensure that all future agreements follow the required processes. View of Responsible Officials: Management agrees with the finding and plans to update their procurement policy.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

Formerly 2021-004: Procurement and Suspension and Debarment: Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program & 16.576 Crime Victims Compensation Condition: The Organization was unable to demonstrate controls over the procurement for six items selected for testing. Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract. Questioned Costs: There were six expenditures where no documentation could be provided to support that the expense took place during grant period resulting in a questioned question cost of $2,699 for 14.267 and $12,739 for 16.567 Effect: The Organization could have expenditures that were paid that did not meet its own procurement policy. Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy. Perspective: This is a systemic issue in that controls over the requirement have not been developed to enasure the reported information is accurate. Repeat: This is a repeat finding. Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.

2022-003 U.S. Department of Treasury Federal Financial Assistance Listing # 21.027 Award Years: 2021, 2022 Grant Award Number: Unknown COVID–19 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures and contract requirements required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was noted that the City of Groton’s (the City) procurement policy followed state law which is some cases is less restrictive than federal law. We also noted that the policy does not include the required contract provisions that are needed in contracts with federal grants. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts when federal grants are involved. Questioned Costs: None reported Context/Sampling: All vendors, which totaled two, were selected for procurement testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review Uniform Guidance and 2 CFR sections 200.318 through 200.326 to ensure that all items identified are included in the procurement policy. Views of Responsible Officials: Management agrees with the finding.

2022-003 U.S. Department of Treasury Federal Financial Assistance Listing # 21.027 Award Years: 2021, 2022 Grant Award Number: Unknown COVID–19 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures and contract requirements required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment, it was noted that the City of Groton’s (the City) procurement policy followed state law which is some cases is less restrictive than federal law. We also noted that the policy does not include the required contract provisions that are needed in contracts with federal grants. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect: A lack of established controls increases the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts when federal grants are involved. Questioned Costs: None reported Context/Sampling: All vendors, which totaled two, were selected for procurement testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review Uniform Guidance and 2 CFR sections 200.318 through 200.326 to ensure that all items identified are included in the procurement policy. Views of Responsible Officials: Management agrees with the finding.

Department of the Treasury, Passed through North Dakota State Water Commission Federal Financial Assistance Listing 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - During the course of our engagement, it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with of procurement, suspension, and debarment. Questioned Costs - None reported Context/Sampling - Overall procurement policy. Repeat Finding from Prior Year(s) – No Recommendation - We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials - There is no disagreement with the audit finding.

Material weakness in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Procurement Standards contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Procurement Standards, require that a non‐Federal entity use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. The procurement procedures must include the following: - Using the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). - For acquisitions exceeding the simplified acquisition threshold, using one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of the circumstances are met, in accordance with 2 CFR section 200.320(c)). - Using Noncompetitive procurement only if one or more of the following circumstances apply: · The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; · The item is available only from a single source; · The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; · The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or · After solicitation of a number of sources, competition is determined inadequate PDA’s procurement policy also requires a verification that vendors and sub-recipient are not suspended or debarred by checking the website of the System for Award Management and documentation of such verification maintained by the Finance Office. Condition/Context While PDA has established a procurement policy, it does not fully conform to the Uniform Guidance for the following reasons: - Micro purchase threshold is not explicitly defined, although it is mentioned that cost and price analysis shall be made and documented in connection with every procurement action above $5,000. - The policy did not have clear provisions for maintaining detailed procurement records. Such records should include the rationale for the procurement method, the selection of contract type, the contractor selection or rejection process, and the basis for the contract price. - The simplified acquisition threshold is not defined and does not incorporate all relevant elements including sealed bids method. During our testing of 3 procurement transactions from a total of 15, we observed that, despite management's detailed historical background on each of the selected transactions, the necessary documentation evidencing compliance with PDA’s procurement policy was not retained. All the transactions tested were noncompetitive. The total misstatement is the entire population amount $205,921 as PDA did not maintain sufficient documentation to evidence history of procurement for all procurement transactions. Furthermore, for three vendors, which represented a 100% sample, we found no evidence of documentation for suspension and debarment verification. Although discussions with management suggested that all these transactions were properly conceived and evaluated at the time, there was no contemporaneous documentation to support this. Cause PDA’s procurement policy does not seem to have been reviewed against the Uniform Guidance for compliance. Internal controls over maintaining sufficient records to detail the history of procurement including noncompetitive justification and suspension and debarment verification were found to be insufficient. Effect The absence of a policy that fully conformed to the Uniform Guidance resulted in noncompliance issues such as records sufficient to detail the history of procurement transactions not maintained. Questioned Costs $205,921 Repeat Finding Yes. Recommendation We recommend PDA implement measures to ensure that its procurement policy reflect applicable state and local laws and regulations conforming to applicable federal statutes and requirement in 2 CFR part 200. Management should ensure procurement transactions are documented in such detail to evidence the method of procurement use and vendor verification for suspension and debarment.

Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Procurement. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.319(d) requires that the non-Federal entity must maintain written procedures for procurement transactions. Condition: We noted that the City did not have written procedures for procurement transactions that include the provisions required by the Procurement Standards 2 CFR § 200.318 through 2 CFR § 200.327 in fiscal year 2022. Cause: The City was not aware of the requirement to have written procedures for procurement transactions. Effect: Failure to have adequate written procedures for procurement transactions could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, other procurement requirements, and Uniform Guidance requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop adequate written policies and procedures for procurement transactions. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.

Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Procurement. Type of Finding: Material Weakness in Internal Control Over Compliance. Criteria: Internal controls should be in place to provide reasonable assurance that procurement of goods and services are made in compliance with federal regulations and other procurement requirements, as applicable. Condition: The City lacks sufficient controls over procurement to ensure compliance with federal regulations and other procurement requirements, as applicable. Cause: The City did not design and implement controls over compliance with procurement. Effect or Potential Effect: Failure to have adequate internal controls over compliance with procurement could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, and other procurement requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City create and adopt an official written policy for procurement and contracts establishing contract files that document significant procurement history; methods of procurement authorized including selection of contract type, contractor selection or rejection, and the basis of contract price; verification that procurements provide full and open competition; requirements for cost or price analysis, including for contract modifications; obtaining and reacting to suspension and debarment certifications; and other applicable requirements for procurements under federal awards are followed. We also recommend that personnel with adequate knowledge and experience of responsibilities for procurements for federal awards review procurement and contracting decisions for compliance with federal procurement policies. Views of Responsible Officials and Planned Corrective Action: Management concurs with the audit finding. The City will develop written policies and procedures for procurement, including the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions. Management will evaluate the need to contract with local government consultants to perform control procedures where City personnel are not available or qualified to perform.

Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Procurement. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.319(d) requires that the non-Federal entity must maintain written procedures for procurement transactions. Condition: We noted that the City did not have written procedures for procurement transactions that include the provisions required by the Procurement Standards 2 CFR § 200.318 through 2 CFR § 200.327 in fiscal year 2022. Cause: The City was not aware of the requirement to have written procedures for procurement transactions. Effect: Failure to have adequate written procedures for procurement transactions could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, other procurement requirements, and Uniform Guidance requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop adequate written policies and procedures for procurement transactions. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.