Findings Citing § 200.327

Identification of the Federal Program: U.S. Department of Housing and Urban Development: AL 14.267 – Continuum of Care Program Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant deficiency in internal controls over compliance. Criteria 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Statement of condition and cause The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Effect Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with the Uniform Guidance. Questioned Costs N/A Repeat Finding No Recommendation We recommend that management develop a written procurement policy that conforms with the Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Management response See Corrective Action Plan

2026-004 Procurement Program Information Federal Organization U.S Department of Health and Human Services Assistance Listing Numbers 93.224 Health Center Program Cluster Award Numbers H80CS00513 Criteria [X] Compliance Finding [] Significant Deficiency [X] Material Weakness Title 2 CFR 200.318 requires that entities receiving federal awards must have and use their documented procurement policies and these policies must be consistent with state and local laws and regulations and the standards identified in §200.317 through 200.327. Condition The Organization did not follow its documented procurement policy. Cause Management did not follow its established procurement policy, and documentation was not maintained evidencing its compliance with the policy, such as obtaining competitive bids and documenting sole-source vendor justifications. Effect The Organization may overpay for goods and services due to selecting vendors without appropriate consideration of the competitive bids and cost analysis. Questioned Costs $39,478 Context In a sample of 40 invoices, we noted six with issues related to the procurement process. Organization did not follow their established procurement policy and did not retain appropriate documentation of competitive bids. Recommendation We recommend that the Organization maintain adequate documentation supporting reports submitted to awarding agencies and update its procurement policy to align with 2 CFR 200.320(c). Views of responsible officials and planned corrective action Management is in agreement with this finding and will take corrective action as outlined on page 34.

Environmental Protection Agency, Passed through North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.327 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’s policy on procurement did not satisfy the requirements of 2 CFR sections 200.318 through 200.327 with regards to procurement levels and methods, conflicts of interest, and contract provisions. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under 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) –Yes, prior year finding 2024-005 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 200.327 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. View of Responsible Officials - There is no disagreement with the audit finding.

Internal Control over Compliance or Compliance Findings Criteria: Uniform Guidance §200.318 (General Procurement Standards) requires recipients and subrecipients to maintain and follow documented procurement procedures for transactions under a Federal award or subaward. These procedures must be consistent with applicable State, local, or tribal laws and regulations, as well as the standards set forth in 2 CFR §§200.317–200.327. Documentation must include, at a minimum, the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for contract pricing. In addition, recipients must ensure vendors are not suspended or debarred from participation in federal programs. Condition: Although the Organization followed procurement requirements in practice, including appropriate procurement methods, documentation of vendor selection, and verification that vendors were not suspended or debarred, it did not have formal, written procurement and suspension/debarment policies in place during the audit period. Cause: The Organization relied on established operating practices and staff knowledge to ensure compliance with federal procurement requirements. As a result, these practices were not formally documented in written policies aligned with 2 CFR Part 200. Effect: While no instances of noncompliance or questioned costs were identified, the absence of formal written policies increases the risk that procurement and suspension/debarment procedures may not be applied consistently in the future or adequately demonstrated during audits or monitoring reviews. Recommendation: We recommend that the Organization formally document its existing procurement and suspension/debarment practices in written policies that comply with 2 CFR Part 200. Views of Responsible Officials: Management agrees with the finding. The Organization notes that all federal procurement and suspension/debarment requirements were followed during the audit period and has formalized these practices in written policies for future federal awards.

Finding Number: 2025-006 Finding Type: Federal award finding Federal Assistance Listing No.: 15.685 Program Name: National Fish Passage Federal Agency: The U.S. Department of Interior Pass-Through Entity: n/a Grant Number: F24AC01768-00 Award Project Period: July 1, 2024 through July 1, 2029 Control Deficiency Type: Significant deficiency Instance of Noncompliance: Yes Compliance Requirement: Procurement, suspension and debarment Repeat Finding: No Criteria: A non-federal organization must follow its own documented procurement procedures, provided they comply with applicable state and local laws and align with the federal standards outlined in 2 CFR 200.318–200.327. Specifically, 2 CFR 200.318(i) requires entities to maintain records sufficient to detail the history of the procurement, including but not limited to the rationale for the procurement method chosen, the basis for selecting or rejecting contractors, and the justification for the contract price. In addition, all procurement transactions must be conducted in a manner providing full and open competition. Furthermore, federal requirements prohibit grant recipients from contracting with, or purchasing from, contractors who are suspended and debarred from doing business with the federal government. Whenever the organization enters into contracts or purchases goods or services with federal funds that it expects to equal or exceed $25,000, it must verify that the contractor or vendor has not been suspended, debarred or otherwise excluded. Finally, the organization must ensure that all federal programs comply with Section 70914 of the Build America, Buy America (BABA) Act for infrastructure projects. Condition: The Council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with BABA. Cause: This was the Council’s first year receiving direct federal funding and its first Single Audit. The organization is very small and has limited prior experience with federal procurement requirements. Effect: The absence of aligned written procurement policies and timely documentation increases the risk of non-compliance with federal procurement standards. While no unallowable costs were identified and the contractor was not suspended or debarred, the issues reflect a control deficiency in procurement documentation, suspension and debarment procedures, and monitoring of federal award requirements. Questioned Costs: None. Audit Recommendation: We recommend the Council: • Update its procurement policy to align with federal procurement methods, thresholds, and requirements. • Develop written procedures for technical evaluations, contractor selection, and documentation of procurement decisions. • Perform suspension and debarment verification prior to contract award. • Establish monitoring procedures for contractor compliance with federal award provisions, including Build America, Buy America Act requirements. Management’s Response: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grant-required stipulations such as BABA requirements, monitoring, compliance, and documentation.

Finding – Reporting – Congressional Grants; Assistance Listing Number 59.059; 9/1/22-8/31/27 Award Period, U.S. Small Business Administration Criteria or Specific Requirement Recipients must use the standard financial reporting forms or such other forms as may be authorized by OMB when reporting to the federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. Financial reporting requirements for cost reimbursement contracts subject to the FAR are contained in the terms and conditions of the contract. Non-profit entities may be required to submit performance reports at least annually but not more frequently than quarterly, using form or format authorized by OMB. (Financial reporting 2 CFR 200.327; Performance reporting 2 CFR 200.301 and 200.329). Condition and Context The Organization's federal award agreement requires SF-425 Federal Financial Report and a performance report to be filed annually. The Organization did not file these reports in 2025 as required. Cause The Organization did not follow the award agreement reporting requirements. Effect The Organization was not in compliance with the Federal Reporting compliance requirement. Identification as a Repeat Finding Not a repeat finding. Questioned Costs None. Recommendation We recommend that management review the reporting requirements in their federal award agreement to identify and file any required reports by applicable due dates. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

Finding – Procurement, Suspension & Debarment - Congressional Grants; Assistance Listing Number 59.059; 9/1/22-8/31/27 Award Period, U.S. Small Business Administration Criteria or Specific Requirement Non-federal entities other than states, must follow the procurement standards set out at 2 CFR 200.318 through 200.327. 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 and Context One procurement transaction for a building construction contract which covers 100% of the major program expenditures was tested. We noted that the expenditures of the major program were for valid allowable activities and costs, however we noted that the procurement, suspension and debarment requirements for a procurement transaction over the simplified acquisition threshold were not followed including, not obtaining competitive bids, missing cost/price analysis, and selecting the contractor primarily on qualifications but without a valid noncompetitive justification. Also, the suspension and debarment search was not conducted however, we noted through a search that the contractor is not suspended or debarred. The sample was not statistically valid. Cause The Organization’s written procurement policy was not followed. Effect The procurement transaction for the federal award was not in compliance with the procurement requirements. Identification as a Repeat Finding Not a repeat finding. Questioned Costs Undeterminable – Questioned costs are costs identified as potentially noncompliant due to a violation of a statute, regulations, or the terms and conditions of a federal award; where costs are not supported by adequate documentation or where costs incurred appear unreasonable, not reflecting actions a prudent person would take in the circumstances. The expenditure incurred was tested and determined to be for valid allowable activities and costs but was not in compliance with the procurement requirements. Recommendation We recommend that the Organization’s procurement policy for purchasing and contracting decisions be distributed and reviewed by all appropriate staff to ensure that the procurement policy is followed and procurement requirements are met. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

2025-001 Procurement, Suspension and Debarment U.S. Department of Education 84.421F Pathways To Success: Creating a 21st Century Workforce 2025 Award Year Criteria: Under 2 CFR §§ 200.318 – 200.327, non-Federal entities must maintain written procurement policies that reflect applicable Federal, State, and local laws and regulations. These policies must include standards of conduct, competition requirements, methods of procurement, contract oversight, and procedures for verifying suspension and debarment. Entities must follow these written policies when procuring goods and services under Federal awards. In addition, in accordance with the Uniform Guidance (2 CFR Part 180), recipients and subrecipients are prohibited from entering into covered transactions with parties that are suspended or debarred. Covered transactions include contracts for goods and services expected to equal or exceed $25,000 and all subawards regardless of dollar amount, unless specifically exempt. Recipients and subrecipients are required to verify that contractors and subrecipients are not suspended or debarred. Universe / Population: The universe / population for Procurement is written procurement policies that reflect applicable Federal, State, and local laws and regulations. The universe / population for Suspension and Debarment was 12 vendors for the year ended December 31, 2025. We haphazardly selected 5 vendors for testing of suspension and debarment compliance requirements applicable to the program. Condition: The Organization does not have a documented written procurement policy that complies with the requirements of 2 CFR §§ 200.318 – 200.327 or documented internal controls to ensure compliance with suspension and debarment requirements. Specifically, the Organization does not have written policies or procedures requiring verification that vendors or subrecipients are not suspended or debarred prior to entering into covered transactions, nor does it consistently document such verification. As a result, the Organization does not have a formal policy framework to guide procurement activities in accordance with Federal procurement standards. Cause: The Organization has not developed written procurement policies that incorporate the specific requirements of the Uniform Guidance, including required verification procedures and documentation standards. Effect: Without a compliant, documented procurement policy and effective internal controls, the Organization is at risk of noncompliance with Federal procurement standards, inconsistent procurement practices, failure to properly verify suspension and debarment, and ineffective internal controls over procurement activities. This condition also increases the risk that required suspension and debarment checks are not performed or documented. Although no questioned costs were identified for the period under audit, the absence of compliant written policies represents a control deficiency in internal control over compliance for procurement requirements. Questioned Costs: None Repeat Finding: No Recommendation: Management should develop and implement written procurement policies and procedures that fully comply with 2 CFR §§ 200.318 – 200.327. The policies should include internal controls to ensure that supporting documentation is maintained for all procurements, including documentation of procurement method determination, price or cost analysis, vendor selection, required approvals, and suspension and debarment verification. View of Responsible Officials: Going forward, Lighthouse Louisiana will ensure that its procurement policy reflects its commitment to purchases made in a manner that promotes full and open competition, supports price reasonableness, and maintains appropriate documentation based on the applicable procurement threshold. Management confirms that the Organization will apply a $10,000 micro-purchase threshold, require price or rate quotations from an adequate number of qualified sources for small purchases between $10,000 and $250,000, and require a formal competitive process for procurements exceeding $250,000, unless a properly documented exception applies. Lighthouse Louisiana did not actively retain all SAM.gov search results in vendor files for each vendor included in the procurement testing; however, if a SAM.gov verification was performed but not retained in the file, management will document the issue, perform and retain an updated verification, and strengthen internal controls to require retention of SAM.gov evidence before agreement execution or renewal. As part of its corrective action, Lighthouse Louisiana will enhance its procurement file review process to ensure that each grant-funded procurement contains, as applicable, the procurement method determination, supporting quotes or price comparisons, price reasonableness analysis, vendor selection rationale, required approvals, contract or agreement, and SAM.gov verification. Management will also reinforce staff training on procurement documentation requirements and will implement a standardized procurement checklist for grant-funded purchases. The Chief Financial Officer, Chief Operations Officer, and Project Director will be responsible for ensuring that any requested documentation is gathered and submitted to the auditors and that procurement file improvements are implemented prospectively.

FINDING 2025-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2021 Pass-Through Entity: Morgan County, Indiana Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Significant Deficiency, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 TOWN OF MOORESVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The Town spent COVID-19 Coronavirus State and Local Fiscal Recovery Fund (SLFRF) award dollars from two sources during the audit period. One source was a direct allocation from the Department of the Treasury (Treasury). The other source was a pass-through from Morgan County, Indiana. Direct Treasury funds that are spent under the revenue loss eligible use category are not subject to the federal procurement requirements set forth in 2 CFR § 200.318-200.327. Because the Town classified all its direct Treasury funds spent during the audit period as revenue loss, federal procurement rules do not apply to those expenditures. However, procurement requirements do apply to the SLFRF funds the Town spent as a subrecipient of Morgan County, Indiana. Procurement - Policy Award funds may be used to procure goods and services necessary to carry out the purpose of the award. The Town must follow its own documented procurement policies and procedures, which must reflect applicable state and federal laws and regulations. The Town did not have a procurement policy or procedures that complied with state or federal laws and regulations for the procurement of goods or services with federal funds. Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases are typically for those purchases $50,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, the price or rate quotations must be obtained from an adequate number of qualified sources. The Town had one vendor that qualified for and was tested under the small purchase procedures. The Town paid this vendor $92,463 during the audit period for a sanitation project but did not obtain the required price or rate quotations. The ineffective internal controls and noncompliance were isolated to the procurement policy and the small purchase identified above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 14 TOWN OF MOORESVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases— (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." Cause Management was unaware of this grant requirement relating to the federal procurement policy and obtaining quotes for federal small purchases. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the Town's compliance with the compliance requirement listed above. The failure to design and implement an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could result in the loss of future federal funds to the Town. INDIANA STATE BOARD OF ACCOUNTS 15 TOWN OF MOORESVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management establish a system of internal controls to ensure that they are in compliance with the grant agreement the Procurement and Suspension and Debarment compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Criteria Recipients and subrecipients 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 200.327. Condition During internal control inquire, we noted the City did not follow federal procurement requirements. The City also entered into a covered transaction without checking the vendor to ensure they did not have an active suspended or debarred exclusion from receiving federal funds. Cause Management oversight Effect The City is not in compliance with federal procurement, suspension, and debarment requirements. Questioned Costs None Recommendation The City should follow their procurement policy. Views of Responsible Officials and Planned Corrective Actions City officials have already implemented internal controls to ensure the proper oversight of federal programs according to the Uniform Grant Guidance Policy for Federal Revenue Sources. Current Status This is a new finding in the current year.

Finding: 2025-005 – Procurement ALN and Title: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of Treasury Passthrough Entity: State of Nevada Governor’s Finance Office Budget Division Type of Finding: Significant Deficiency Criteria: Per 2 CFR §200.318(a), non-federal entities must: “Use their own documented procurement procedures which reflect applicable State, local, and Tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part.” Additionally, 2 CFR §200.318(b) requires non-federal entities to maintain oversight to ensure contractors perform in accordance with the terms, conditions, and specifications of contracts or purchase orders. Condition: The Foundation did not maintain a formal written procurement policy governing purchases made with federal funds during the fiscal year ended December 31, 2025. Cause: Management had not established and formally documented procurement procedures designed to ensure compliance with Uniform Guidance procurement standards Effect: Without a documented procurement policy, the Foundation is at increased risk of noncompliance with federal procurement requirements, including inadequate competition, inconsistent purchasing practices, and insufficient documentation supporting procurement decisions. Questioned Costs: Unknown. Identification of a repeat finding: Not applicable. Context: The Foundation did not have written policies surrounding procurement so formal control procedures were not documented. However, procurement procedures were followed. Recommendation: We recommend the Foundation adopt a formal written procurement policy that complies with Uniform Guidance requirements under 2 CFR §200.317–§200.327. The policy should address procurement methods, competition requirements, conflict of interest standards, documentation requirements, contractor oversight, and suspension and debarment procedures. View of Responsible Management agrees with this recommendation. See prepared corrective action plan Officials: for details.

FINDING 2025-001 Subject: Water and Waste Disposal Systems for Rural Communities - Procurement Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): BAN-2 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 13 CITY OF HUNTINGBURG SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002. Condition and Context As part of sound management of the federal award, the City was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The City had not properly designed or implemented such a system that would likely be effective in preventing, or detecting and correcting, noncompliance. The purchasing policy provided by the City for review did not include the applicable federal regulations, such as procedures to avoid the acquisition of unnecessary or duplicative items and procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Additionally, the City did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in § 200.317 through 200.327." Cause The City did not fully implement the corrective measures stated in the City's corrective action plan prepared in response to this same finding included in the immediately prior audit report. Effect Without a proper system of internal controls in place that operated effectively, the City did not properly follow its corrective action plan and did not update its purchasing policy to reflect the required federal procurement standards. As a result, noncompliance identified in the immediately prior audit remained uncorrected throughout the current audit period. INDIANA STATE BOARD OF ACCOUNTS 14 CITY OF HUNTINGBURG SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City update its purchasing policy to incorporate all appropriate federal regulations to ensure compliance with the procurement standards applicable to federal awards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding No. 2025-002: Subrecipient Monitoring and Procurement and Suspension and Debarment – Noncompliance Federal Program Name: Juvenile Mentoring Program Pass-through Entity: None Federal Assistance Listing Number: 16.726 Criteria Uniform Guidance requires that non-Federal entities ensure that they do not make subawards to entities that are suspended or debarred from participating in Federal programs. Recipients and subrecipients are subject to the non-procurement suspension and debarment regulations set forth in 2 CFR §200.214 and 2 CFR Part 180, which restrict the issuance of Federal awards and subawards to excluded parties. Condition During the audit period, the Partnership issued subawards to subrecipients; however, the Partnership’s current subrecipient policies are missing several critical elements, including procedures to verify that subrecipients are not suspended or debarred by the federal government, requirements to pass applicable federal special conditions down to subrecipient awards, methods to track the total amount of funding provided to subrecipients under each federal program, processes to ensure that payments to subrecipients minimize the time between the transfer of federal funds from the grantee and disbursement to the subrecipient, a risk-based monitoring approach, and an on-site monitoring process that includes reviews of financial and administrative aspects of the program, among other areas. Cause The Partnership had not previously developed or updated its subrecipient monitoring policies to fully align with the requirements of Uniform Guidance. Management relied on informal practices and staff knowledge rather than comprehensive, documented procedures to address suspension and debarment verification, subaward compliance requirements, cash management, and risk-based monitoring. In addition, limited compliance resources and the absence of a centralized compliance review process contributed to gaps in policy development and implementation during the audit period. Effect Without verification of suspension and debarment status, the Partnership is at risk of making subawards to entities that are ineligible to receive Federal funds. This could result in questioned costs, required repayment of Federal funds, or other sanctions imposed by the Federal awarding agency or pass-through entity. Questioned Costs None noted. Context 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 200.327 and must follow the subrecipient monitoring and management standards set out at 2 CFR 200.331 through 200.333. They must use their own documented procurement and subrecipient monitoring procedures, which reflect applicable state and local laws and regulations, provided that the procurements and subawards conform to applicable federal statutes and the procurement and subrecipient monitoring requirements identified in 2 CFR Part 200. Recommendation We recommend that the Partnership implement written policies and procedures to ensure that all subrecipients are verified as not suspended or debarred prior to the execution of subawards. Acceptable methods of verification include reviewing SAM.gov exclusion listings, obtaining written certifications from subrecipients, or incorporating suspension and debarment representations into subaward agreements. Documentation of the verification should be retained in accordance with record retention requirements. Management’s Response/View of Responsible Officials Management agrees with this finding, see the Corrective Action Plan.

FINDING 2025-002 Subject: Assistance to Firefighters Grant - Procurement and Suspension and Debarment Federal Agency: Department of Homeland Security Federal Program: Assistance to Firefighters Grant Assistance Listings Number: 97.044 Federal Award Number and Year (or Other Identifying Number): EMW-2023-FG-06299 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Procurement Federal regulations require recipients of federal awards to maintain documented procedures for procurement under a federal award. These procedures must comply with State, local, and tribal laws, along with applicable provisions under 2 CFR 200.317 through 2 CFR 200.327. These requirements include the avoiding of acquisition of unnecessary or duplicative items, a clear and accurate description of technical requirements for the items or services to be procured, the requirements for solicitations to identify any and all requirements which offerors must fill and other factors to be used in evaluating bids or proposals, and a policy prohibiting the use of statutorily or administratively imposed state, local, or tribal geographical preferences in the evaluation of bids or proposals. The City did not present a procurement policy containing these required provisions for the audit. INDIANA STATE BOARD OF ACCOUNTS 15 CITY OF KENDALLVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Additionally, when the value of the procurement for property or service exceeds the simplified acquisition threshold (SAT), or a lower threshold established by a nonfederal entity, formal procurement methods are required. The SAT is typically set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold. Therefore, the SAT threshold is set at $150,000. Formal procurement methods require adherence to documented procedures and formal methods such as sealed bids or proposals. Federal regulations require a firm-fixed-price contract to be awarded in writing to the lowest responsible and responsive bidder. The City solicited bids for Air-Paks funded through the Assistance to Firefighters Grant. After awarding the bid, the City did not enter into a formal written contract with the vendor. Suspension and Debarment Prior to entering into covered transactions with federal award funds, recipients are required to verify that vendors are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The City did not have policies or procedures in place to verify that vendors were not suspended or debarred before entering into covered transactions. During the audit period, the City entered into one covered transaction for Air-Paks, utilizing $837,350 of federal award monies, which met the $25,000 threshold for verification. However, the City did not verify the vendor's suspension or debarment status prior to payment because no process existed to ensure contractors were not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. . . . INDIANA STATE BOARD OF ACCOUNTS 16 CITY OF KENDALLVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (ii) If sealed bids are used, the following requirements apply: . . . (D) A firm-fixed-price contract will be made in writing to the lowest responsive and responsible bidder. When specified in bidding documents, factors such as discounts, transportation cost, and life-cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause The City did not implement effective internal controls to safeguard their procurement policy. The City's procurement policy was destroyed in a storm, and no backup copies were available. Also, the City was not aware that a formal written contract was needed for procurements exceeding the SAT threshold or the Procurement and Suspension and Debarment compliance requirement when a covered transaction is expected to equal or exceed $25,000. Effect Without the proper implementation of an effectively designed system of internal controls, the City is at risk of noncompliance with the Procurement and Suspension and Debarment compliance requirement, including the potential for a loss of federal funds awarded to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City design and implement a proper system of internal controls, including policies and procedures, to ensure the City complies with the Procurement and Suspension and Debarment compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 17 CITY OF KENDALLVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

U.S Department of Health and Human Services Federal Financial Assistance Listing #93.493 Congressional Directives Procurement, Suspension & Debarment Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200. 303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards to Uniform Guidance standards in sections 2 CFR 200.317 through 200.327. Additionally, 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are applicable. Condition: Testing of the federal program identified the following: 􀁸 The Hospital’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. 􀁸 Instances where the Hospital did not follow the procurement process, and/or retain documentation for reasoning of selection of vendor. Cause: The Hospital was not aware of the federal procurement requirements and did not have an established policy. Contract provisions were not evaluated compared to Uniform Guidance contract requirements and documentation was not retained to support procurement and selection of vendors. Effect: The Hospital was not in compliance with the procurement standards for their purchases and are not in compliance with the requirement to have a written policy in accordance with Uniform Guidance. Questioned Costs: None reported. Context: A nonstatistical sample of 4 out of 14 vendors were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital update their procurement policy to ensure it includes all the required elements in accordance with Uniform Guidance. In addition, we suggest that management implement procedures and control processes related to the review of procurement to ensure the procurement methods are being followed and documentation is retained to support compliance. Views of Responsible Officials: Management agrees with the finding.

Department of Treasury, State of Iowa Department of Management, Federal Financial Assistance Listing 21.029, 526659, 2025 COVID-19 Coronavirus Capital Projects Fund Procurement, Suspension & Debarment Material Weakness in Internal Control over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to the procurement standards in sections 200.317 through 200.327. Condition: Testing of the federal program identified the following: --One instance where the Cooperative did complete price comparisons; however, the memo documenting the procurement did not reference the price comparison. The procurement file did not obtain all required components of the procurement process including rationale for selecting the vendor or the procurement method used. --One instance where the Cooperative did not follow the procurement process as detailed in the procurement policy and no documentation was retained to support the rationale for selection of vendor. Cause: The Cooperative followed parts of the procurement policy in place, however, not all components were documented and retained within the procurement file. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Cooperative would be noncompliant with the compliance requirements outlined above. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 3 out of 6 vendors were selected for testing. Repeat Finding from Prior Year: Yes, finding 2024-002 Recommendation: We recommend that management implement procedures and control processes related to the review of contracts to ensure the procurement methods are being followed and documentation is retained to support the method of procurement. Views of Responsible Officials: Management agrees with the finding.

Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Federal Agency: United States Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Federal Award Identification Number and Year: 2022-70423-38069, 2021-70030-35719 Award Period: Project period: multiple; Budget period: multiple Questioned Costs: None Statement of Condition NMFMA did not have adequate controls over the SF-425 reporting timeline. For two out of two SF-425 Federal Financial Reports tested, the annual and close-out reports were submitted after the due date (90 days for annual and close-out reports). Also, the annual report seems to have some clerical errors and the amounts reported did not match the general ledger for the period reported, due to markets payments being reconciled late. The difference is immaterial, and client will adjust in the next report. CriteriaIn accordance with 2 CFR 200.327 (Financial Reporting) and award terms requiring SF-425 is required to be submitted for the Food Insecurity Nutrition Incentive Grants program. Recipients use the SF-425 as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status. The due dates are 30 days after the end of the reporting period for quarterly reports, and 90 days after the end of the reporting period for the annual and close-out reports. Also, the reports need to be reviewed for accuracy and completeness. CauseNMFMA has not properly implemented a formal reporting calendar, responsibility matrix, or documented pre-submission tie-out/review due to staff turnover. EffectNoncompliance with reporting requirements; risk of USDA sanctions; risk that SEFA and drawdown monitoring rely on inaccurate data. RecommendationEstablish an SF-425 compliance calendar with automated reminders; assign preparer and independent reviewer roles; perform a documented tie-out (SF-425 to GL, bank, and SEFA) with sign-offs before submission; NMFMA staff should improve internal controls by implementing reminders with the due dates of the reports and reviewing the accuracy of the reports before submission. View of Responsible OfficialThe Executive Director will take action to make sure USDA reports are filed on time. The ED will work with the Finance Director and other accounting staff to ensure deadlines are met. TimelineTarget implementation September 30, 2026. Staff Responsible Executive Director

Finding 2025-001 Internal control deficiency and noncompliance over procurement and suspension and debarment and special tests and provisions. Identification of the federal program: Assistance Listing Number 93.493: • Congressional Directives • U.S. Department of Health and Human Services • Federal award identification number – CE147096 • Federal award year – September 1, 2022 to August 31, 2025 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 Internal controls. The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 General procurement standards (a) the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327; (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders; (c) (1) the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 General procurement standards (i) 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. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.319 Competition (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and 200.320. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 Methods of procurement to be followed. The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price; (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 Methods of procurement to be followed. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) 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 (5) After solicitation of a number of sources, competition is determined inadequate. Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.324 Contract cost and price. (a) The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 Suspension and debarment. Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Title 2, Subtitle A, Chapter I, Part 180, Subpart C 180.300 What must I do before I enter into a covered transaction with another person at the next lower tier? When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking SAM Exclusions; (b) Collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. The Health Resources and Services Administration (HRSA) project guidance requires the following: • Federal Interest – Real Property – For all construction projects, regardless of award amount, you are required to file a Notice of Federal Interest (NFI). The NFI requires prior written approval in order for the property owner to mortgage, sell, transfer, or use the property for a purpose inconsistent with the award. A notarized NFI must be filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and once filed, a copy must be provided to the appropriate HRSA Grants Management Specialist. Condition: During our testing over procurement, we observed management did not have documented procurement procedures that conformed to the procurement standards identified in 2 CFR section 200.318 to 200.327 and written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Management did not have internal controls in place over small purchase procurements to ensure price or rate quotations were obtained from an adequate number of qualified sources, formal procurements to ensure sealed bids or proposals were obtained through public advertising, and completion of a cost or price analysis in connection with all procurement actions exceeding the simplified acquisition threshold. Management did not maintain records for procurements to document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. During our testing over suspension and debarment, we observed management did not have documented suspension and debarment procedures and did not have internal controls in place to ensure vendors were searched for suspension and debarment at the time of vendor selection. During our testing over special tests and provisions, we observed management did not file an NFI against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and provide to the appropriate HRSA Grants Management Specialist. Cause: Management did not have internal controls in place over the compliance requirements as stated in the criteria or specific requirement section above. Effect or potential effect: Procurements were not supported by internal controls and could potentially include unreasonable prices or rates. In addition, if a search for suspension and debarment is not conducted, the entity could contract with vendors that are suspended or debarred. Special tests and provisions were not supported by internal controls in that an NFI was not filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located. Questioned costs: $1,154,000 – Assistance Listing Number 93.493 – Congressional Directives – Federal award identification number – CE147096 Questioned costs were computed as the entire population of procurement transactions subject to small purchase, formal procurement, suspension and debarment, and special tests and provisions compliance requirements. Questioned costs means a cost that is questioned by the auditor because of an audit finding: (1) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds or (2) where the costs, at the time of the audit, are not supported by adequate documentation. Context: During our testing over procurements, we obtained a listing of expenditures that included $1,154,000 of procurement transactions subject to small purchase, formal procurement, suspension and debarment, and special tests and provisions compliance requirements. We observed management did not have internal controls in place to ensure the compliance requirements as stated in the criteria or specific requirement section above were performed. Identification as a repeat finding, if applicable: No. Recommendation: Management should create documented procurement procedures that conform to the procurement standards identified in 2 CFR section 200.318 through 200.327 and written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Management should develop and implement internal controls over small purchase procurements to ensure price or rate quotations are obtained from an adequate number of qualified sources, formal procurements to ensure sealed bids or proposals are obtained through public advertising, and completion of a cost or price analysis in connection with all procurement actions exceeding the simplified acquisition threshold. Management should maintain records for procurements to document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Management should create documented suspension and debarment procedures and develop and implement internal controls to ensure vendors were searched for suspension and debarment at the time of vendor selection. Management should review the procurements identified as questioned costs to identify if any improper payments were made to the entity. Management should develop and implement internal controls over special tests and procedures to ensure that an NFI is filed against the property deed prior to construction in the appropriate public records office of the jurisdiction in which the property is located and provide to the appropriate HRSA Grants Management Specialist. Views of responsible officials: We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised in accordance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist.

Finding 2025-002 – Policies and Procedures Require Review and Update – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Significant Deficiency Condition & Cause: The Housing Authority has not adequately reviewed and updated several policies and procedures necessary to provide current guidance to employees and ensure compliance with applicable federal requirements and generally accepted internal control practices. Specifically, we noted: 1. The capitalization policy establishes a $500 threshold for capitalization and tracking of nonexpendable equipment. The threshold has contributed to difficulty maintaining an accurate inventory of equipment, including appliances. 2. The investment policy was adopted in December 2009 and has not been updated to reflect current requirements and practices. 3. The Housing Authority does not have a comprehensive financial policies and procedures manual addressing the flow of financial documents, internal controls over Housing Authority assets, authorization procedures, financial reporting responsibilities, and segregation of duties. 4. The Housing Authority does not have a formal conflict-of-interest policy applicable to Board members and employees. 5. The procurement policy was last revised April 23, 2024. The policy states that Board of Commissioners approval is not required for any procurement action. The current policy also establishes informal procurement thresholds of up to $40,000, with requirements for three quotations for purchases between $10,000 and $40,000 and sealed bids for purchases exceeding $40,000. The conditions appear to have resulted from an inadequate process for periodically reviewing and updating policies to reflect changes in federal requirements, HUD guidance, and the Housing Authority's current operations. Criteria: 2 CFR §200.303(a) requires a recipient or subrecipient to establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards. 2 CFR §200.303(c) further requires management to evaluate and monitor compliance and §200.303(d) requires prompt action when instances of noncompliance are identified. With respect to procurement, 2 CFR §200.318(a) requires the recipient or subrecipient to maintain and use documented procurement procedures that are consistent with applicable State, local, and tribal laws and regulations and the Federal procurement standards contained in 2 CFR §§200.317–200.327. 2 CFR §200.318(c)(1) also requires written standards of conduct covering conflicts of interest for employees involved in the selection, award, and administration of contracts. HUD's Public Housing Procurement Handbook 7460.8 states that PHAs are required to establish and follow a written procurement policy consistent with 2 CFR §§200.317–200.327. The Handbook also addresses the authority and responsibility of the PHA Board for approving the procurement policy and delegating procurement authority. The Housing Authority's own Board-approved procurement policy establishes procurement thresholds and procedures that are required to be followed unless properly amended by the Board. Accordingly, the Housing Authority is required to maintain policies that are consistent with applicable Federal requirements and to administer procurements in accordance with its approved policies. Effect: Outdated or incomplete policies increase the risk that employees will not have adequate guidance to perform their responsibilities consistently and that the Housing Authority will not comply with applicable federal, HUD, state, and local requirements. In particular, the absence of comprehensive financial policies and procedures and an updated procurement policy increases the risk of unauthorized transactions, inadequate competition, unsupported procurements, conflicts of interest, inadequate segregation of duties, and inconsistent treatment of Housing Authority transactions. Recommendation: We recommend that the Housing Authority conduct a comprehensive review of all financial, procurement, investment, capitalization, conflict-of-interest, and other significant administrative policies at least annually and whenever applicable federal or HUD requirements change. Specifically, the Housing Authority should: • Revise the capitalization policy and establish a threshold that is practical to administer while maintaining adequate control over material nonexpendable equipment; • Update the investment policy to reflect current requirements and investment practices; • Develop and formally adopt a comprehensive financial policies and procedures manual; • Develop and implement a formal conflict-of-interest policy applicable to Board members, employees, and other applicable parties; • Revise the procurement policy to reflect current federal and HUD requirements, including HUD Handbook 7460.8, Rev. 3 and applicable provisions of 2 CFR Part 200; • Establish clear Board approval requirements for significant procurement contracts and other material commitments; and • Establish a formal process for management and the Board to periodically review and approve policy updates. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Criteria Title 2 CFR §200.318(a), requires a non-Federal entity to maintain and use documented procurement procedures that conform to the procurement standards contained in 2 CFR §§200.317 through 200.327. Condition The Organization did not maintain documented procurement procedures that incorporated the procurement standards required by Uniform Guidance. During the year ended December 31, 2025, HUD funds were used to reimburse costs associated with a mixed-finance capital construction project. The general contractor for the project was selected prior to the commitment of HUD funding for the project. The grant agreement disclosed a contractor was already selected Cause Management had not previously administered federal funding for a capital construction project subject to Uniform Guidance procurement standards and accordingly had not developed formal written procurement procedures conforming to 2 CFR §§200.317 through 200.327. In addition, the general contractor was selected prior to the commitment of HUD funding to the project. Effect The absence of documented procurement procedures increases the risk that procurements funded in whole or in part with federal awards may not comply with applicable federal procurement requirements. This condition represents a significant deficiency in internal control over compliance and noncompliance with the Procurement and Suspension and Debarment compliance requirement. Questioned Costs None ($0). Context This finding relates to the Economic Development Initiative major program (ALN 14.251). This is the first year the program was audited as a major program and therefore is not a repeat finding. Recommendations We recommend the Organization develop, formally adopt, and implement written procurement procedures that conform to the requirements of 2 CFR §§200.317 through 200.327 and apply those procedures to all procurement activity funded in whole or in part by federal awards. Views of Responsible Officials Management agrees with the finding and will develop and implement written procurement procedures consistent with Uniform Guidance requirements.

FINDING 2025‐002 – Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Assistance Listing Number: 21.029 Federal Program Name: COVID-19 - Coronavirus Capital Projects Fund Award Year: 2024 Criteria: Uniform Guidance requires non-federal entities to establish and adhere to documented procurement procedures and ensure compliance with suspension and debarment requirements. 2 CFR §200.318(a): Requires entities to have and use documented procurement procedures consistent with federal standards. 2 CFR §200.318(i): Requires maintenance of records sufficient to detail the history of procurement. 2 CFR §200.214: Prohibits contracting with parties that are suspended or debarred, requiring verification. Condition and context: The Cooperative has not developed or implemented formal written procurement policies and procedures that comply with Uniform Guidance requirements. Additionally, the Cooperative has not established procedures to ensure compliance with suspension and debarment requirements. As a result, for a sample of two vendors and nine procurement transactions tested, the Cooperative did not document suspension and debarment verification (e.g., SAM.gov) for vendors and contractors procured under the federal award. The absence of documented procedures also indicates that procurement activities are not being performed under a standardized framework aligned with federal requirements. Questioned costs: None. Effect: Due to the lack of formalized procurement processes and controls there is an increased risk of noncompliance with federal procurement standards. Expenditures could be paid to suspended or debarred vendors resulting in disallowed expenditures, and noncompliance with the grant agreement. Cause: Management did not have a sufficient understanding of the procurement-related control requirements necessary to comply with the grant agreement and Uniform Guidance. As a result, procurement processes were not formally established or aligned with federal requirements. Repeat finding: Yes. Recommendation: We recommend the Cooperative develops and implements written procurement policies and procedures in compliance with 2 CFR §200.318–§200.327, including competitive procurement requirements, cost/price analysis, documentation, and record retention. Establish procedures to ensure compliance with suspension and debarment requirements, including performing SAM.gov verification prior to contract award and retaining documentation of verification in procurement files. Lastly, we recommend implementing monitoring controls to ensure procurement documentation and compliance requirements are consistently met. Views of responsible officials and planned corrective actions: Wabash currently maintains the process of procurement standards and internal controls. While we previously managed contractor selections through established internal practices, we recognize the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash implemented a formal Procurement Policy and Procedure June 30, 2026. Contact Person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer

Criteria: The Uniform Guidance procurement standards are located in 2 CFR, Subpart D, Sections 200.317 through 200.327. All organizations are required to follow specific procurement standards when making major purchases with federal funds, including purchases of supplies, property, equipment, real property, and services. Procurement and Suspension and Debarment compliance requires that (1) recipients establish and follow written procurement procedures that conform to applicable federal statutes and procurement requirements identified in 2 CFR part 200 and (2) contracts and subawards under covered transactions not be made with parties listed on the General Services Administration's System for Award Management (SAM) Exclusions (debarred, suspended, otherwise excluded, or declared ineligible) Condition: Management has an established procurement policy. However, during our testing of a non-statistical sample of three procurements for the year ended December 31, 2025, we identified the following exceptions: • For one procurement tested, management did not document a formal cost/price analysis, and a competitive bid was not obtained. • For another procurement tested, the contract was a covered contract over $25,000; however, management did not document review of whether the contractor was suspended or debarred. Sikich performed a search of SAM (or the applicable exclusion listing) and noted the contractor was not listed as suspended or debarred; however, management did not retain documentation evidencing its verification procedures. Cause: The condition appears to have resulted from insufficient controls to ensure procurement files include required documentation supporting (1) the basis for vendor selection (including competitive procurement support and cost/price analysis, where applicable) and (2) verification that contractors on covered transactions are not suspended or debarred prior to contract execution. Effect: The lack of required procurement documentation increases the risk that procurements are not made in accordance with procurement requirements and the Organization’s procurement policy. In addition, lack of documented verification of suspension and debarment status increases the risk the Organization could enter into covered transactions with ineligible contractors, which could result in unallowable costs and noncompliance with federal requirements. Questioned Costs: None identified. Although management did not document its suspension and debarment review for the covered contract tested, Sikich’s search noted the contractor was not suspended or debarred. In addition, no specific dollar disallowance was identified from the procurement documentation exceptions based on procedures performed. Perspective: The finding was identified during testing of the Organization’s major program for the year ended December 31, 2025. We tested a non-statistical sample of three procurements and identified two exceptions Recommendation: We recommend that management strengthen internal controls over procurement and suspension/debarment compliance and implement a standardized procurement file checklist to document key requirements for each procurement, including the procurement method, evidence of competition (as applicable), and documented cost/price analysis, where required. We also recommend that management require retention of documentation evidencing verification that contractors are not suspended or debarred for covered transactions (for example, a dated SAM Exclusions search result or equivalent evidence) prior to contract execution.

Section II – Financial Statement Findings None reported. Section III – Federal Program Audit Findings and Questioned Costs Finding Number: 2025-001 Finding: Finding Type: Material Weakness Title and Federal Assistance Listing Number of Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition. For purchases exceeding the micro-purchase threshold of $10,000, the entity must obtain price or rate quotations from an adequate number of qualified sources, unless the purchase qualifies as a sole-source procurement under 2 CFR 200.320(c). Additionally, 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Furthermore, 2 CFR 200.318(b) and 200.324 require that written contracts be executed with contractors, including all required Federal provisions to safeguard Federal funds. Condition: We examined 60 transactions during our testing of procurement transactions under the Coronavirus State and Local Fiscal Recovery Funds. We noted that a competitive bidding process was not used in 32 of 60 transactions tested. In all 32 instances, Historic South did not provide evidence that multiple bids or quotes were solicited. The documentation and explanation provided by Historic South was not deemed to be adequate justification to qualify for the use of sole-source procurement under 2 CFR 200.320(c). Additionally, all 60 procurement transactions tested did not have a fully executed, signed contract with the respective contractors. The award/contracting process and methods used to render and pay services did not meet the expected level of formal contractual agreements in place. Cause: In early 2024, Historic South made revisions to the procurement process in order to maximize efficiency and improve overall project outcomes. These revisions were made based on the challenges of securing bids on all potential projects, the need to expend the awarded dollars in a timely fashion and a verbal agreed-upon understanding with the Ohio Department of Health. The requirement to obtain multiple bids was replaced with a strategic invitation approach based on a preferred vendor pool. The result was that Historic South did not have a procedure in place to ensure that procurement transactions were conducted in compliance with Uniform Guidance. Specifically, the procurement policy lacked provisions to enforce competitive procurement practices for purchases above the micro-purchase threshold. Additionally, the process Historic South used to make awards to contractors did not meet the expected standards required for formal contract execution prior to project initiation or payment. - 29 - Historic South Initiative Schedule of Findings and Questioned Costs - continued Year Ended December 31, 2025 Section III – Federal Program Audit Findings and Questioned Costs - continued Effect: Failure to obtain competitive bids or quotes increases the risk of paying higher prices for goods/services, or unfair contracting practices. Additionally, the lack of competitive procurement represents noncompliance with Uniform Guidance, which may lead to questioned costs and potential disallowance by the granting agency. Furthermore, the lack of formally signed contracts increases the risk of misuse of federal funds and an inability to enforce contractual obligations or resolve disputes. While our testing did not identify any instances of misspent or improperly used federal funds, the control deficiencies represent a material weakness in internal control over compliance. Questioned Costs: $1,000,798 These costs are considered questioned due to lack of compliance with Uniform Guidance. The amount represents the total bid/contract amount of the 32 transactions tested that did not meet the competitive bidding requirements. Recommendation: We recommend that Historic South implement and enforce formal procurement procedures that comply with the requirements of 2 CFR 200.317-200.327. These procedures should include obtaining competitive bids and/or maintaining documentation for any alternative bidding process used and approval requirements. Additionally, Historic South should require that fully executed, signed contracts be obtained prior to the start of work or payment to contractors. Staff responsible for procurement should be trained on federal procurement standards to ensure compliance. Views of Responsible Official and Planned Corrective Action: Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 audit occurred before the corrective measures became effective. Corrective measures implemented include policies and procedures designed to strengthen its procurement and contracting processes. These include: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work Management believes these corrective actions address the deficiencies identified and expects them to be fully effective for construction activities occurring after implementation.

Finding: 2025-002 Procurement, Suspension and Debarment Federal Agency(ies): United States Department of Defense Federal Program(s): Research and Development Cluster Assistance Listing Number(s): 12.300, 12.330 Pass-through Entity (if applicable): Direct awards and pass-through awards from RTI International and Greensight, Inc. Award Identification Number and Year: Various Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR 200.317 through 2 CFR 200.327, non-Federal entities are required to maintain documentation sufficient to detail the history of procurement transactions. Such documentation should include, as applicable, the rationale for the method of procurement, contractor selection, basis for contract price, and the basis for any sole-source procurement. Additionally, pursuant to 2 CFR 180 and 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred and should maintain documentation demonstrating that applicable vendors were screened prior to contracting or payment. Condition: As part of our testing of vendor expenditures charged to Federal awards within the Research and Development Cluster, we selected a statistical sample of procurement transactions and noted deficiencies in RoboNation's procurement and suspension and debarment documentation. Specifically, we noted instances in which RoboNation did not consistently document the rationale supporting its selection of vendors charged to Federal awards. In addition, for procurements utilizing a sole-source or noncompetitive procurement methodology, RoboNation did not consistently document which of the allowable exceptions under 2 CFR 200.320 justified the use of noncompetitive procurement. With respect to suspension and debarment requirements, we noted that RoboNation did not consistently maintain evidence that vendors were screened against the System for Award Management (SAM.gov) database prior to contracting or payment. We also identified instances in which SAM.gov screening reports were either undated or dated after execution of the vendor agreement and related payment activity. Cause: RoboNation's policies and procedures for procurement documentation and suspension and debarment compliance were not operating effectively. Specifically, controls were not sufficient to ensure that procurement files contained required support for vendor selection and sole-source procurements, nor were controls adequate to ensure that SAM.gov screenings were completed and documented prior to engaging vendors charged to Federal awards. Effect or Potential Effect: The lack of adequate procurement and suspension and debarment documentation increases the risk that procurement transactions may not comply with Uniform Guidance requirements and that vendors could be selected without sufficient support for the procurement method utilized. Additionally, the lack of timely and documented SAM.gov screenings increases the risk that Federal funds could be expended on vendors that are suspended or debarred from participation in Federally funded programs. Questioned Costs: $437,591 Context: As part of our testing of the Procurement, Suspension, and Debarment compliance requirements for the Research and Development Cluster, we selected a statistical sample of vendor transactions charged to Federal awards during the year ended December 31, 2025. Identification as a Repeat Finding, if Applicable: Yes, repeat of 2024-003. Recommendation: We recommend that management strengthen controls over procurement and suspension and debarment compliance by implementing procedures requiring procurement files to contain documentation supporting vendor selection, the procurement method utilized, and, when applicable, the specific basis for sole-source procurement under Uniform Guidance. In addition, management should establish procedures to ensure that SAM.gov screenings are performed and documented prior to contract execution or payment and that evidence of such screenings is retained within the procurement file.

Finding 2025-001 Federal Program Habitat Conservation Assistance Listing Number 11.463 Federal Agency U.S. Department of Commerce Finding Type Significant Deficiency in Internal Control Over Compliance Compliance 1. Compliance Requirements Allowable Costs/Cost Principles — Uniform Guidance requires written procedures for determining allowability of costs, tied to 2 CFR 200.302(b)(7). 2. Cash Management — 2 CFR 200.302(b)(6) requires written procedures to implement the cash management requirements in 2 CFR 200.305. 3. Procurement and Suspension and Debarment — 2 CFR 200.318–200.327 require documented procurement procedures, and 2 CFR 200.318(c) requires written standards of conduct for employees involved in contractor selection, award, and administration. Questioned Costs None Criteria Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In addition, the Uniform Guidance includes certain written policy requirements applicable to non-federal entities, which may include, as applicable, written procedures for determining the allowability of costs, written cash management procedures, written procurement procedures, standards of conduct covering conflicts of interest, and other written policies or procedures required by the specific compliance requirements applicable to the federal program. Condition During our audit, we noted that the Organization did not have a comprehensive set of written policies and procedures addressing key Uniform Guidance requirements applicable to the administration of federal awards. Cause Management indicated that the Organization has historically relied on informal practices, institutional knowledge, and existing general written accounting policies to administer federal awards. However, these policies had not been formally updated to incorporate the specific written policy and procedural requirements of the Uniform Guidance. Repeat Finding? No Effect/Potential Effect Without formal written policies and procedures that address Uniform Guidance requirements, the Organization is at increased risk that compliance with federal awards may not be maintained if laws and regulations change, if knowledgeable staff turnover occurs, and that the Organization may be required to repay federal awards if costs are questioned or disallowed. Recommendation We recommend that management review the Uniform Guidance requirements applicable to the Organization’s federal award programs and update its written policies and procedures to specifically address all required written policy areas. At a minimum, the updated policies should address the written policy and procedure requirements applicable to the Organization’s federal programs, such as: • Procedures for determining the allowability of costs charged to federal awards; • Cash management procedures, if applicable; • Procurement standards and written procurement procedures, if applicable; • Standards of conduct addressing conflicts of interest related to procurement and federal award administration; • Subrecipient monitoring procedures, if applicable; • Procedures for maintaining supporting documentation and demonstrating compliance with federal award requirements; and • Any additional written policy requirements included in the federal award terms and conditions or applicable compliance supplement. Management should ensure that the updated policies are formally approved, communicated to appropriate personnel, and reviewed periodically for continued compliance with current Uniform Guidance requirements and federal award terms and conditions. Views of Responsible Officials and Correct Action Plan Management agrees with the finding. The Organization acknowledges that it does not currently have written policies and procedures addressing certain required Uniform Guidance compliance areas. Management will develop, approve, and implement written policies and procedures designed to comply with applicable Uniform Guidance requirements, including policies over allowable costs/cost principles, cash management, and procurement, including suspension and debarment. Management will also communicate the new policies to relevant personnel and provide training as needed to support consistent implementation

Criteria An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in 2 CFR § 200.317 through 200.327. For purchases below the simplified acquisition threshold (SAT) but above the micro-purchase threshold, 2 CFR § 200.320(a) requires the non-Federal entity to obtain price or rate quotations from an adequate number of qualified sources. Condition The Program used federal grant funds to pay a single contractor $222,080 in the aggregate for installation services performed at individual homes. As a small purchase under 2 CFR 200.320(a), the procurement required the Program to obtain price or rate quotations from an adequate number of qualified sources. The Program did not solicit or document quotations from more than one source prior to engaging the contractor. Cause The Program was not fully educated on procurement policies when it came to grant funds, so they were not aware that bids or price comparisons were necessary for the purchases. Effect Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed or subject the entity to possible claims. Recommendation We recommend management adhere to the Federal, State, and local regulations for all procurements using Federally sourced funds by ensuring policies and procedures are documented and followed in accordance with Uniform Guidance requirements. Management's Response Management agrees with our recommendation and finding and will work to adhere to all applicable procurement policies. Questioned Costs None. Although the Program did not follow the required competitive procurement procedures for this contractor, the costs incurred were reasonable and allowable under the terms of the Federal award and applicable cost principles. The deficiency relates to noncompliance with procurement standards, not to the propriety of the costs themselves; accordingly, no costs are questioned.

Finding 2025-001 – Inadequate Documentation Supporting Compliance with Federal Procurement Requirements Federal Agency: U.S. Department of Treasury passed through Kansas Department of Commerce Federal Program: COVID-19, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal award identification number and year: SLFRP0140 - 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Pursuant to 2 CFR §§ 200.214, 200.319, and 200.327, non-Federal entities are required to verify that covered parties are not suspended or debarred from participation in Federal programs, conduct procurements in a manner providing full and open competition, and include applicable Federal award provisions in contracts funded by Federal awards. Condition: During testing of procurement contracts, we noted the following exceptions: • Certain contracts did not contain the applicable Federal contract provisions required by Appendix II to 2 CFR Part 200. Management indicated that the omission of the required provisions was identified through monitoring performed by the grant administrator acting on behalf of the pass-through entity and efforts were subsequently initiated to amend the affected contracts. • One contract below the questioned cost threshold lacked documentation demonstrating the procurement was conducted in a manner providing full and open competition. • One contract lacked documentation supporting the required price/cost analysis. • One contract lacked documentation evidencing performance of suspension and debarment verification procedures. Consequently, the Organization lacks controls to demonstrate compliance with certain Federal procurement requirements. Context: The exceptions identified above affected six contracts, representing approximately 17% of the procurement expenditures tested within the Procurement, Suspension, and Debarment compliance requirement. Based on audit procedures performed, the related expenditures were determined to be allowable costs, supported by appropriate documentation, and incurred in furtherance of the grant's objectives. Cause: The Organization did not maintain effective controls to demonstrate compliance with Federal procurement requirements. Effect: The Organization could not demonstrate compliance with certain Federal procurement requirements related to contract provisions, competition, and suspension and debarment. Questioned costs: None noted. Recommendation: We recommend the Organization implement procedures to ensure Federal procurement requirements, including contract provisions, competition requirements, and suspension and debarment verification, are performed, documented, and retained for all covered procurements. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Program: COVID-19 - Coronavirus Capital Projects Fund Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.029 Pass-Through Agency: Wisconsin Department of Administration Pass-Through Agency ID: FFP 24-33 Criteria: In accordance with 2 CFR §§ 200.318 and 200.327, non-Federal entities must maintain written procurement procedures that comply with the Uniform Guidance procurement standards. These procedures must include written standards of conduct governing conflicts of interest, establish procurement methods consistent with the federal procurement thresholds and require price or rate quotations from an adequate number of qualified sources for small purchases exceeding the micro-purchase threshold. Condition: The City's procurement policy does not comply with the procurement requirements of the Uniform Guidance. The policy does not include written conflict of interest standards applicable to employees, officers or agents involved in the selection, award or administration of contracts funded with federal awards. The policy establishes a $25,000 threshold for procurement procedures, which does not align with the federal procurement methods established under the Uniform Guidance. The policy does not address the federal micro-purchase threshold of $10,000 (or the applicable threshold adopted under federal regulations) or require price or rate quotations from an adequate number of qualified sources for purchases exceeding the micro-purchase threshold. The City contracted with a third-party administrator who provided the appropriate services related to procurement for this grant program. Cause: Management has not updated the City's procurement policy to incorporate the procurement standards required by the Uniform Guidance. Effect: Without procurement policies that comply with Uniform Guidance requirements, the City is at increased risk of noncompliance with federal procurement regulations. This may result in questioned costs, disallowed expenditures, repayment of federal funds, audit findings or other enforcement actions by the federal awarding agency or pass-through entity. Questioned Costs: None noted. Recommendation: We recommend the City revise and formally adopt a procurement policy that complies with 2 CFR Part 200. The policy should establish written standards of conduct that address organizational and personal conflicts of interest; update procurement thresholds to align with current federal procurement methods and thresholds; and require price or rate quotations from an adequate number of qualified sources for procurements exceeding the federal micro-purchase threshold. Views of Responsible Officials: Management agrees with the finding and will make efforts to implement a formal procurement policy.

Finding 2025-001 – Reporting FEDERAL PROGRAM INFORMATION: - Workforce Innovation and Opportunity Act (WIOA) – A.L.N.# 17.258/259/278 - Temporary Assistance for Needy Families (TANF) – A.L.N.# 93.558 CRITERIA: 2 CFR 200.327 and 200.328 require that performance and financial reports be accurate, current, and complete. Reports must be supported by the accounting records from which they are prepared. CONDITION: We noted that the monthly financial reports for WIOA and TANF submitted during FY 2025 did not reconcile to the County’s underlying accounting records. CONTEXT: We selected twelve monthly reports for the WIOA program, and twelve monthly reports for the TANF program, and we noted for the reports selected, amounts reported did not agree to the supporting documentation. CAUSE: The County identified additional grant expenses or disqualified certain grant expenses and revised existing expenses charged to the grants after the reports were submitted, but the reports had already been filed and could not be amended. EFFECT: Submitting reports that do not agree to the accounting records may result in inaccurate reporting to the federal awarding agency. This increases the risk of misstating program expenditures, potential questioned costs, and reduced confidence in the accuracy of reported data used for program oversight. QUESTIONED COSTS: None RECOMMENDATION: We recommend the County identify all eligible expenses and revisions prior to reporting submissions.

Finding 2025-002 – Earmarking FEDERAL PROGRAM INFORMATION: - Workforce Innovation and Opportunity Act (WIOA) – A.L.N.# 17.258/259/278 CRITERIA: - 2 CFR 200.302(b)(3): Recipients must maintain records that adequately identify the source and application of Federal funds. - 2 CFR 200.327–328: Financial and performance reports must be accurate, current, and complete. - OMB Compliance Supplement (Part 4, earmarking section): Requires that a specified portion of expenditures be used for certain categories, which must be verifiable through the accounting system. CONDITION: During our testing of earmarking requirements for the WIOA, we were unable to perform the required calculations because the financial data reported to the awarding agency did not reconcile to the County’s underlying accounting records. Due to these identified discrepancies, we were unable to verify earmarking requirements. CONTEXT: We selected twelve monthly reports for the WIOA program, and we noted for the reports selected, amounts reported did not agree to the underlying accounting records and thus we could not verify compliance with earmarking requirements. CAUSE: The County has not implemented effective reconciliation procedures to ensure that reports submitted to the awarding agency agree to the underlying accounting records. Additionally, there is no validation of the accuracy of expenditures reported for earmarking purposes. EFFECT: Because the submitted reports did not reconcile to the accounting records, we were unable to determine whether the County complied with the earmarking requirements of the program. QUESTIONED COSTS: None RECOMMENDATION: We recommend the County identify all eligible expenses and revisions prior to reporting submissions so that accurate information is available to ensure compliance with earmarking requirements.

Finding 2025-002 Type of Finding: Material weakness in internal control over compliance and instance of immaterial noncompliance Compliance requirement: Procurement and suspension and debarment Criteria: Uniform Guidance procurement standards require nonfederal entities to use documented procurement procedures and maintain procurement policies and procedures that conform to applicable federal requirements for procurement transactions under a federal award. Condition: Willamette Health Council did not have written procurement policies and procedures that conform to, or contain all required elements of, the Uniform Guidance procurement standards. Although Willamette Health Council did not have compliant written procurement policies, there were no procurements tested (and none identified by management) with expenditures exceeding the applicable micro-purchase threshold during the audit period. Cause: Willamette Health Council had not established and implemented formal, written procurement policies and procedures aligned with Uniform Guidance requirements, including periodic review and updates to ensure continued compliance. Effect / Potential Effect: While no procurements exceeding the micro-purchase threshold were identified during the audit period (and therefore the instance of noncompliance is considered immaterial), the absence of compliant written procurement policies represents a deficiency in the design of internal control over compliance. Without properly designed procurement policies and procedures, there is an increased risk that future procurement transactions may not be conducted in accordance with the Uniform Guidance and that noncompliance may not be prevented, detected, or corrected on a timely basis. Accordingly, this condition is considered a material weakness in internal control over compliance. Questioned Costs: None. Context/Perspective: Per review of Willamette Health Council expenditure records, procurement transactions during the period totaled $18,683; and all of which were under $10,000 thus, the micropurchase threshold applied. Repeat Finding: Not applicable. There was no prior year audit. Recommendation: We recommend that Willamette Health Council develop, approve, and implement written procurement policies and procedures that conform to the Uniform Guidance procurement standards outlined in 2 CFR §200.318 through §200.327. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement, Suspension and Debarment Program: COVID-19 - Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Pass-Through Agency: Wisconsin Department of Administration Pass-Through Agency ID: FFP 24 06 Criteria: In accordance with 2 CFR §§ 200.318 and 200.327, non-Federal entities must maintain written procurement procedures that comply with the Uniform Guidance procurement standards. These procedures must include written standards of conduct governing conflicts of interest, establish procurement methods consistent with the federal procurement thresholds and require price or rate quotations from an adequate number of qualified sources for small purchases exceeding the micro-purchase threshold. Condition: The Village's procurement policy does not comply with the procurement requirements of the Uniform Guidance. The policy does not include written conflict of interest standards applicable to employees, officers or agents involved in the selection, award or administration of contracts funded with federal awards. The policy does not establish a simplified acquisition threshold for formal procurement procedures, to align with the federal procurement methods established under the Uniform Guidance. The Village contracted with a third-party administrator who provided the appropriate services related to procurement for this grant program. Cause: Management has not updated the Village's procurement policy to incorporate the procurement standards required by the Uniform Guidance. Effect: Without procurement policies that comply with Uniform Guidance requirements, the Village is at increased risk of noncompliance with federal procurement regulations. This may result in questioned costs, disallowed expenditures, repayment of federal funds, audit findings or other enforcement actions by the federal awarding agency or pass-through entity. Questioned Costs: None noted. Recommendation: We recommend the Village revise and formally adopt a procurement policy that complies with 2 CFR Part 200. The policy should establish written standards of conduct that address organizational and personal conflicts of interest and update procurement thresholds to align with current federal procurement methods and thresholds. Views of Responsible Officials: Management agrees with the finding and will make efforts to implement a formal procurement policy.

2025-002: Procurement and Suspension and Debarment (Significant Deficiency Over Internal Control) Program: Coronavirus State and Local Fiscal Recovery Funds-American Rescue Plan Act (ARP) ALN 21.027; Passed through Oregon Department of Administrative Services; grant award numbers 22-072N and 33500. 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 200.327. 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. 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 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR 180.215. 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 for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300). Condition: The Organization did not appropriately monitor expenditures for the vendor tested to trigger verification of the vendor status of suspension or debarment prior to the expenditures reaching the $25,000 covered transaction threshold. Additionally, the Organization's procurement policy does not fully comply with federal procurement standards outlined in the Uniform Guidance. Specifically, the policy lacks required elements such as documented competitive procurement thresholds, cost or price analysis requirements, and provisions addressing conflicts of interest and contract oversight. Cause: The noncompliance was caused by the absence of documentation to evidence that suspension and debarment checks had been completed prior to contracting or issuing subawards and lack of formal monitoring process to ensure policies remain current and compliant with Uniform Guidance requirements. Effect: The absence of maintaining a procurement policy that aligns with federal requirements increases the risk of noncompliant purchasing practices, which could lead to questioned costs, disallowed expenditures, and potential repayment of federal funds. Questioned Costs: No questioned costs were identified. Recommendation: We recommend the Organization update the language in their procurement policy to fully align with federal procurement requirements as outlined in the Uniform Guidance and to reflect current requirements surrounding covered transactions and suspension and debarment requirements. Additionally, we recommend they strengthen their processes and internal controls to ensure appropriate review of vendors periodically to ensure compliance with procurement, suspension and debarment requirements. View of Responsible Officials and Planned Corrective Action: The Organization agrees with the finding outlined and is working to update their procurement policy, and implement additional vendor review procedures to strengthen internal controls necessary to ensure compliance requirements are met.

Finding 2025-002: Procurement, Suspension and Debarment Federal Agency: U.S. Agency for International Development (USAID) Federal Program: Foreign Assistance for Programs Overseas Assistance Listing Number: 98.001 Pass-through Entity (if applicable): Not applicable Award Identification Number and Year: All Criteria or Specific Requirement: 2 CFR 200.318 through 200.327; 2 CFR 200.303 Recipients and subrecipients must maintain and use documented procurement procedures consistent with applicable laws and the Federal procurement standards. Procurement transactions must be conducted using an appropriate method, with records sufficient to support the procurement history and required determinations. The standards also address competition, conflicts of interest, contractor oversight, cost or price analysis when applicable, required contract provisions, and suspension and debarment requirements. Condition: For several procurement transactions sampled, Internews Network was unable to provide some or all documentation necessary to support compliance. Missing items included procurement method determination, solicitation or quotations, bid/proposal evaluation, sole-source justification, price reasonableness or cost/price analysis. Accordingly, we were unable to determine whether the transactions were procured in accordance with Internews Network’s policies, 2 CFR 200.318 through 200.327, and applicable award terms. Cause: Management indicated that significant staffing reductions followed the termination of Federal awards and funding. Procurement and grants administration duties were dispersed or discontinued without a complete transition of electronic and paper records. Management did not have an enforced, centralized procurement file standard or a closeout control designed to confirm that each procurement file was complete before responsible staff separated. Effect or Potential Effect: The missing documentation prevented verification that procurement transactions were conducted with the required competition, approvals, price considerations, exclusion checks, and contract terms. This increases the risk of unsupported vendor selection, unreasonable costs, transactions with excluded parties, omitted Federal clauses, and costs that may be challenged by a Federal agency or pass-through entity. Questioned Costs: Undetermined Context: Internews Network used Federal award funds to acquire goods and services under during the audit period. Compliance with Federal procurement requirements is ordinarily demonstrated through a contemporaneous procurement file documenting the applicable method, competition or authorized noncompetitive justification, vendor selection, price or cost considerations, approvals, exclusion checks, contract terms, and oversight. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: Implement a standardized procurement checklist scaled to method and threshold. Retain the funding source, threshold and method determination, competition or approved noncompetitive justification, vendor responses, evaluation, price support, conflicts documentation, exclusion verification, approvals, contract provisions, invoices, and oversight evidence. Require independent completeness reviews before award and final payment, centralize records, and use a staffing-reduction or award-termination protocol to transfer ownership, preserve access, and certify file completeness.

Finding 2025-005 Noncompliance over Procurement Significant deficiency/ Noncompliance Criteria: The Organization should establish and maintain written procurement procedures to ensure that purchases and contracts supported by federal awards are conducted in accordance with applicable federal procurement standards, including required full and open competition and required methods of procurement. The Uniform Guidance procurement standards are contained in 2 CFR Part 200, Subpart D, §§ 200.317–200.327 generally, including 2 CFR § 200.319 (Competition) and 2 CFR § 200.320 (Methods of procurement to be followed). Condition and Context: During our testing of the Organization’s procurement compliance requirements, we noted two contracts that should have been procured using competitive bidding; however, the Organization did not complete competitive bidding for these contracts. Cause: The Organization did not have sufficient procedures in place to ensure that procurement actions were consistently evaluated for required competitive procurement methods and that compliance with applicable procurement requirements was documented and reviewed prior to contract award. Effect: Failure to follow applicable competitive procurement requirements may result in noncompliance with federal procurement standards and may increase the risk that contracts are awarded without maximizing open and free competition. In addition, inadequate procurement documentation reduces management’s ability to demonstrate that procurement actions are conducted in accordance with applicable requirements. Questioned Costs: None noted. Repeat Finding: This is not a repeat finding. Recommendation: Management should establish or strengthen procurement policies and procedures to ensure that contracts subject to competitive procurement requirements are competitively bid and that procurement actions are appropriately documented. Such procedures may include developing standardized procurement checklists, requiring supervisory review of procurement method selection and documentation prior to contract award, and providing periodic training to staff responsible for procurement. Management Response: Management concurs with this finding. See Corrective Action Plan.

The District did not have written procurement procedures or a procurement policy in effect for procurements related to the project funded under ALN 66.202, Congressionally Mandated Projects, for the year ended December 31, 2025, as required by 2 CFR §§ 200.318–200.327. The District did have a conflict-of-interest policy.

Assistance Listing Number: 93.193 Name of Federal Program: Urban Indian Health Services; COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2025 – December 31, 2025 Criteria or Specific Requirement: Per 2 CFR Part 200, non-federal entities receiving federal awards must establish and maintain written policies and procedures addressing areas including, but not limited to: procurement (§200.317–§200.327); travel costs (§200.475); methods for avoiding duplication of costs (§200.403); subrecipient monitoring (§200.332); cash management and allowable costs (§200.302, §200.305). Condition: The organization has not implemented all policies and procedures required under the Uniform Guidance. Specifically, certain written policies and procedures required by 2 CFR Part 200, such as cash management, allowability of costs, equipment management, conflict of interest, procurement, travel, compensation, and fringe benefits, were either incomplete, not formally documented, or not in place during the audit period. Cause: Due to timing constraints and a small staff size, the Council has not detailed its policies to conform with the requirements of the Uniform Guidance. Effect or Potential Effect: Without documented and implemented policies and procedures, the organization increases the risk of noncompliance with federal regulations, inconsistent application of requirements, unallowable costs being charged to federal awards, and potential questioned costs or sanctions from funding agencies. Repeat Finding: Yes, this is a repeat of Finding 2024-003. Recommendation: Management should develop, formally adopt, and implement all required Uniform Guidance policies and procedures. Policies should be documented, communicated to relevant staff, and periodically reviewed to ensure ongoing compliance. Views of Responsible Officials: Management agrees with the finding and revise its policies and procedures to meet the criteria of the Uniform Guidance.

Finding 2025-005 AL No.: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of Treasury Pass-through Agency: Wisconsin Department of Health Services Award Number/Year: Unknown/ 2025 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 200.327. Per 2 CFR 200.319, the entity is to conduct all procurement transactions in a manner providing full and open competition and the procurement method was appropriate based off of the dollar amount and conditions specified in 2 CFR 200.320 and the entity's procurement policy. Condition/Context: The County did not go out for bid for a project above the required dollar threshold in their policy therefore not providing full and open competition and did not have controls in place to ensure the policy was being followed for one of nine of the selected vendors. The sample was not statistically valid. Cause: The County did not have internal control procedures in place to ensure the procurement policy was being followed. Effect: The County could miss out on the best pricing for a project. Questioned Costs: The amount of questioned costs, if any, could not be determined. Recommendation: We recommend the County ensure all employees are aware and familiar with the County procurement policy. Management Response: Staff will be informed of the procurement policy specific to Federally funded projects requiring three bids

Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of Treasury Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2025 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness Criteria: Federal regulations 2 CFR section 200.318 through 200.327 and 2 CFR 180.300 require the City to: 200 CFR.318 (a): The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. 200 CFR.320 (b-c) states in part: Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require the following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (3) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) 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 (5) After solicitation of a number of sources, competition is determined inadequate Finding 2025-001 (Continued) Criteria (Continued) 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person.” Condition: An effective system of internal controls was not in place at the City to ensure compliance with requirements related to the Procurement and Suspension and Debarment compliance requirement. Cause: Management had not established and implemented a system of internal controls and written procedures to ensure compliance with the Procurement and Suspension and Debarment compliance requirement, including the use of formal procurement methods when required and documenting suspension and debarment verification for applicable contracts. Effect: The failure to design and implement an effective system of internal controls enabled noncompliance with the Procurement and Suspension and Debarment compliance requirement to occur and go undetected. Noncompliance with the Procurement and Suspension and Debarment compliance requirement could have resulted in questioned costs or the loss of federal funds to the City. Questioned Costs: There were no questioned costs identified. Context: There was one procurement selected for testing for which The City did not follow federal procurement requirements for a professional services contract totaling approximately $442,200, which exceeded the City's small purchase threshold of $10,000. The City contracted with a firm to perform the design services for the Ohio River Greenway Trail Design Project; however, a formal procurement method was not used for the purchase as required by the federal procurement requirements outlined in 2 CFR § 200.320. Additionally, for the same contract, representing the procurement selected for testing, the City did not document that it verified the contractor was not suspended or debarred from participation in federal award programs prior to awarding the contract exceeding $25,000, as required by 2 CFR § 180.300. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the City's management establish and implement written federal procurement policies to supplement its organizational policies and develop a system of internal controls and written procedures to ensure compliance with grant agreement requirements and the Procurement and Suspension and Debarment compliance requirement. We further recommend that management document the use of the appropriate procurement method and perform and retain documentation of suspension and debarment verification for all covered transactions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.

Condition 2025-02 The Organization did not have written procedures for determining the allowability of costs charged to Federal awards. In addition, the Organization did not have documented procurement policies and procedures governing procurement transactions under Federal awards. Criteria 2 CFR Section 200.302(b)(7) requires a recipient or subrecipient's financial management system to provide for written procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200 and the terms and conditions of the Federal award. 2 CFR Section 200.318(a) requires a recipient or subrecipient to maintain and use documented procedures for procurement transactions under a Federal award. The procedures must conform to applicable Federal, State, and local laws and regulations and the standards identified in 2 CFR Sections 200.317 through 200.327. Cause The Organization had not established and implemented formal written policies and procedures to govern Federal award expenditures and procurement activities. Effect The absence of written allowable cost and procurement procedures increases the risk that Federal funds may be used for costs that are not allowable under the terms and conditions of the Federal award or that procurement transactions may not comply with applicable Federal requirements. Recommendation We recommend that the Organization establish, document, and implement written procedures for determining the allowability of costs charged to Federal awards. We also recommend that the Organization establish and implement documented procurement procedures addressing, at a minimum, procurement methods, competition requirements, contractor selection and evaluation, cost and price analysis, contractor responsibility, conflicts of interest, suspension and debarment, applicable contract provisions, procurement records, and other requirements applicable to Federal awards. Views of Responsible Officials In 2026, written procedures governing the allowability of costs charged to Federal awards and procurement activities involving Federal funds were developed, documented, and implemented. Responsibility for implementing and maintaining these procedures has been assigned to the Finance Department. The procedures address applicable Federal requirements for determining allowable costs and procurement activities and will be reviewed periodically and updated as necessary to maintain compliance with applicable Federal requirements.

Finding 2025-004: Procurement Material Noncompliance and Material Weakness in Internal Control over Compliance Federal Program: Health Center Program (Assistance Listing 93.224) Criteria: Federal procurement standards require non-Federal entities to maintain procurement records sufficient to detail the history of the procurement, including the rationale for the method of procurement, contractor selection, and the basis for contract price. Micro-purchases may be awarded without soliciting competitive quotations only if the non-Federal entity considers the price to be reasonable. Small purchase procedures require price or rate quotations from an adequate number of qualified sources. Noncompetitive (sole-source) procurements may be used only in limited circumstances and must be supported by documentation demonstrating the applicable justification. Additionally, management is responsible for establishing and maintaining effective internal controls to provide reasonable assurance that procurement transactions comply with applicable federal requirements. Condition: Management represented that the procurement method is identified and documented for purchases charged to federal programs. However, the Organization does not have a formal review and approval process to verify that the procurement method selected is appropriate, adequately supported, and documented in accordance with federal procurement requirements. During testing of 68 procurement transactions charged to the Health Center Program, we noted the following exceptions: Thirteen procurements were identified as sole-source procurements; however, no documentation was maintained to support the use of the noncompetitive procurement method or demonstrate that one of the allowable sole-source criteria was met. Sixteen procurements were identified as micro-purchases; however, no documentation was maintained to support price reasonableness or demonstrate that the aggregate procurement transaction qualified for micro-purchase treatment. Thirty-six procurements were identified as micro-purchases; however, based on the aggregate value of purchases with the vendor, the procurements exceeded the micro-purchase threshold and should have been procured using, at a minimum, small purchase procedures requiring price or rate quotations from an adequate number of qualified sources. Cause: Management has not established a formal review and approval process to verify the accuracy of procurement method determinations or ensure procurement documentation is maintained in accordance with federal requirements. As a result, purchases are not consistently evaluated for aggregation, price reasonableness, competitive procurement requirements, or sole-source justification prior to being charged to the federal program. Effect: Because procurement methods are not subject to an effective review and approval process, there is an increased risk that purchases may not be procured using the method required under federal regulations or may lack sufficient supporting documentation. Consequently, the Organization cannot demonstrate compliance with federal procurement requirements, including requirements related to competition, price reasonableness, and sole-source procurements. Questioned Costs: Undeterminable. Although the purchases were supported by invoices and were recorded as program expenditures, management did not maintain sufficient documentation to support the procurement method utilized or compliance with applicable procurement requirements. As a result, we could not determine the amount of federal expenditures, if any, that would have been different had the procurements been conducted in accordance with federal procurement standards. Context: During our testing of 68 procurement transactions charged to the Health Center Program, 65 transactions were identified with procurement documentation deficiencies. Exceptions included unsupported sole-source procurements, micro-purchases lacking documentation of price reasonableness, and purchases classified as micro-purchases that exceeded the applicable threshold when evaluated in the aggregate and should have been subject to more stringent procurement procedures. These exceptions indicate a systemic deficiency in controls over procurement method determinations, documentation, review, and approval. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management implement formal procedures requiring review and approval of procurement method determinations before purchases are charged to federal programs. Procedures should include documenting aggregate purchase evaluations, retaining evidence supporting price reasonableness for micro-purchases, obtaining and retaining required quotations for small purchases, documenting any sole-source justification, and maintaining procurement records sufficient to support compliance with federal procurement requirements. Management should also implement an independent review process to verify that procurement documentation is complete and the procurement method selected is appropriate and compliant with federal regulations. Management Response: Management concurs with the finding. The Organization recognizes that procurement procedures and related documentation requirements were not consistently followed and that adequate controls were not in place to ensure compliance with federal procurement standards. Management will conduct a comprehensive review of procurement policies and procedures and will implement formal review requirements for procurement method determinations. To support these efforts, management is hiring a Purchasing Coordinator who will be responsible for all aspects of the Organization’s procurement function and for ensuring that all purchases are conducted in accordance with the Organization’s written procurement policies and the procurement standards of the Office of Management and Budget (OMB) Uniform Guidance (2 CFR 200.317 through 200.327). Additional procedures will require documentation of price reasonableness, competitive quotations, sole-source justifications, and aggregate vendor purchase evaluations, as applicable. The Purchasing Coordinator will determine and document the appropriate procurement method for each purchase, obtain and retain required quotations, and maintain complete procurement files for all purchases charged to federal awards. Personnel involved in purchasing activities will receive additional training on Uniform Guidance procurement requirements, and management will implement monitoring procedures to verify compliance on an ongoing basis. To maintain appropriate segregation of duties, the Accounting Department will independently review procurement files before payment to verify that documentation is complete and that the selected procurement method is appropriate and compliant with federal requirements.

Department of Energy and Passed through Nebraska Department of Environment and Energy Federal Financial Assistance Listing 81.254, 2025-150224869 Grid Infrastructure Deployment and Resilience Procurement, Suspension & Debarment Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards in sections 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are applicable. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contract with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: Testing of expenditures under the federal program identified opportunities to strengthen the District’s procurement and vendor compliance documentation practices. Specifically: -The District has not formalized and adopted a written procurement policy. - In two instances involving covered transactions exceeding $25,000, documentation was not retained to demonstrate that a verification was performed to confirm the vendor was not suspended or debarred from participation in federally funded programs. - In two instances, supporting documentation was not maintained to demonstrate the procurement method utilized and the basis for vendor selection. Cause: Covered transactions were not evaluated compared to Uniform Guidance as it relates to procurement methods and suspension and debarment. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the District would be noncompliant with the compliance requirements outlined above. Additionally, the District may enter into a covered transaction with a vendor that is suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 2 out of 5 vendors were selected for testing. Repeat Finding from Prior Year: No Recommendation: We recommend the District implement a procurement policy that complies with Uniform Guidance. In addition, we suggest that management implement procedures and control processes related to the review of covered transactions to ensure the procurement methods are being followed and any contracts include the required Uniform Guidance provisions. Also, management should ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into work with the vendor. Views of Responsible Officials: Management agrees with the finding.

Assistance Listing Number: 93.193 Name of Federal Program: Urban Indian Health Services; COVID-19 Urban Indian Health Services Name of Federal Agency: Department of Health and Human Services Award Period: January 1, 2025 – December 31, 2025 Criteria or Specific Requirement: Per 2 CFR Part 200, non-federal entities receiving federal awards must establish and maintain written policies and procedures addressing areas including, but not limited to: procurement (§200.317–§200.327); travel costs (§200.475); methods for avoiding duplication of costs (§200.403); subrecipient monitoring (§200.332); cash management and allowable costs (§200.302, §200.305). Condition: The organization has not implemented all policies and procedures required under the Uniform Guidance. Specifically, certain written policies and procedures required by 2 CFR Part 200, such as cash management, allowability of costs, equipment management, conflict of interest, procurement, travel, compensation, and fringe benefits, were either incomplete, not formally documented, or not in place during the audit period. Cause: Due to timing constraints and a small staff size, the Council has not detailed its policies to conform with the requirements of the Uniform Guidance. Effect or Potential Effect: Without documented and implemented policies and procedures, the organization increases the risk of noncompliance with federal regulations, inconsistent application of requirements, unallowable costs being charged to federal awards, and potential questioned costs or sanctions from funding agencies. Repeat Finding: Yes, this is a repeat of Finding 2024-003. Recommendation: Management should develop, formally adopt, and implement all required Uniform Guidance policies and procedures. Policies should be documented, communicated to relevant staff, and periodically reviewed to ensure ongoing compliance. Views of Responsible Officials: Management agrees with the finding and revise its policies and procedures to meet the criteria of the Uniform Guidance.

Criteria or Specific Requirement – Management is required to ensure that there are sufficient internal controls in place over program purchasing. This includes use of the Authority’s own documented procurement procedures which reflect applicable state and local law regulations, provided that the procurements conform to applicable federal law and standards. As well as, internal controls that ensure that documentation is maintained to support compliance with the procurement policy. Conditions – The Authority has a formalized procurement policy (the policy). However, the policy does not conform to applicable standards under Uniform Guidance because it does not include procedures to ensure the Authority does not enter into covered transactions with entities that are debarred, suspended, or otherwise excluded. We noted during our testing that there was limited documentation of the Authority's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Context – During our testing of procurement, we sampled eight expenditures totaling $641,520 consisting of transactions with three companies. We noted that four of the selections with one company totaling $250,774 did not have SAMS.gov verification or compliance certification documentation. However, as part of our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website. Cause – Procurement policy was not sufficient to ensure full compliance. Effect or Potential Effect – The use of non-approved vendors could have occurred. However, as part of our audit procedures, we determined that the expenditures were made with contractors which were not suspended or disbarred and were approved on the SAMS.gov website. Recommendation – We recommend that management strengthen their formal procurement policy using the guidance of 2 CFR 200.317 –200.327. Additionally, management should follow this policy when procuring services or property and maintain the related documentation. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. Management is in the process of reviewing and revising its policies.

2025 002 Reporting and Procurement U.S. Department of the Treasury: Passed through State of New Jersey Department of Community Affairs: COVID 19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Contract Number and Years: G2022 09 (03/02/2021 – 12/31/2026) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample Repeat Finding: Yes (2024 001) Finding Type: Material Weakness, Material Noncompliance Criteria Reporting Per 2 CFR 200.502, the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non Federal statutes, regulations and the terms and conditions of Federal awards, such as: expenditures/expense transactions associated with awards including grants. Further, the Uniform Guidance compliance supplement notes, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the Federal awarding agency. In accordance with the grant agreement and the reporting requirements for the State of New Jersey Department of Community Affairs, direct grants and pass through funds are fulfilled utilizing an advanced payment method and tracking reports. The grantee shall submit quarterly financial reports, in a format to be provided by the Department, and including the number of government full time employees responding to COVID 19 as supported by this funding. The reports are prepared and submitted to allow for relevant and reliable information to be provided to the Federal government or State of New Jersey for tracking purposes. The reports are the source documents for the grantee to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the grantee’s financial statements in accordance with 2 CFR 200.502, Basis for determining Federal awards expended, for the SEFA. Procurement 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 200.327. 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. A non Federal entity must: 1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. 3. Use 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 $50,000 ($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 200.320(a)(1)(ii)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(a)(2)(i)). In accordance with the grant agreement and the reporting requirements for the State of New Jersey Department of Community Affairs, recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in sections 602(c) and 603(c) of the Act and Treasury’s Interim Final Rule and Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. Under the program, St. Joseph’s Health, Inc. must follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. Internal Control 2 CFR 200.303 requires non Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition and Context Reporting On a quarterly basis, St. Joseph’s Health, Inc. (the System) prepares and reports to New Jersey Department of Community Affairs (the Department) the program expenditures for Federal funding amounts on the tracking report of expenditures, which are then used to prepare the annual SEFA in conjunction with the general ledger detail at the end of the fiscal year. While expenditures per the SEFA as prepared by the System were accurate and the quarterly reporting was accepted by the State, the System’s expenditures per the report of expenditures continue to be based upon purchase order amounts, which include expenditures that were incurred subsequent to year end. Procurement Further, the System engaged multiple vendors for several projects under the G2022 09 grant that were above the $50K micro purchase threshold, but below the simplified acquisition threshold. However, the System did not obtain multiple quotes from different vendors to encourage fair competition in the market. The System’s policies and procedures to ensure compliance with the above compliance requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the System properly reported costs on the report of expenditures or obtained the necessary quotes from potential bidders for procurements over the micro purchase threshold. Cause Management did not properly design adequate review procedures to ensure that expenditures reported on financial reports to the Department were reconciled to the System’s accounting records and reflected expenditures incurred. Consequently, purchase order commitments were reported in lieu of incurred expenditures, resulting in a variance of approximately $1.9 million between amounts reported on financial reports to the Department and amounts reported on the SEFA. We noted, however, that this variance did not represent any unallowable costs. Additionally, Management did not retain or obtain the required documentation indicating quotes from multiple vendors were obtained for the ongoing construction projects under the grant. Effect The System had a material variance in the amount of expenditures reported on financial reports to the Department as compared to the SEFA and did not obtain multiple quotations from vendors when making selections for various projects ongoing under the Federal program. Questioned Costs None Recommendation Reporting We recommend that the System strengthen its processes and internal controls to ensure that only allowable and incurred expenditures and not purchase order amounts, are reported on the financial reports submitted to the Department in the applicable period in which they were incurred. Procurement We recommend that the System strengthen its processes and internal controls to ensure that all procurement related transactions are supported by the appropriate bidding documentation as required by the Uniform Guidance for each respective bidding threshold. View of Responsible Official Management agrees with the auditor’s finding and will strengthen its processes and internal controls to ensure the report of expenditures provided to the Department has a reconciliation of the amount of expenditures incurred in the period compared to the purchase order balances and all procurement transactions contain the required bidding documentation for each bidding threshold in accordance with the Uniform Guidance.

Finding 2025-001: Procurement – Significant Deficiency Assistance Listing Number: 12.632 Criteria: 2 CFR Section 200.318 requires that the non-federal entity must have and use documented procurement procedures, consistent with state, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity’s documented procurement procedures must conform to the procurement standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition: During testing of the Institute’s controls over procurement and compliance with procurement requirements, we identified instances where the Institute did not have all the needed documentation around the procurement process. Cause: The Institute did not have formal written procurement policies and procedures during the year to ensure compliance with applicable Federal procurement requirements. Effect: The Institute was not fully compliant with the procurement requirements of the Uniform Guidance. Questioned costs: None Repeat Finding: No. Recommendation: We recommend the Institute review its current processes and controls over procurement to ensure all required documentation is retained and available and implement a formal written procurement policy. Views of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

2025-002 Department of the Treasury, Passed through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2025 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.327 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 Cooperative’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.327. 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. 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 200.327 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 and the Cooperative is in the process of updating the policy to include all required Uniform Guidance components for the year ended December 31, 2026.

Department of Energy, Federal Financial Assistance Listing 81.254, DE-GD0000886, 2025 Grid Infrastructure Deployment and Resilience Procurement, Suspension & Debarment Material Weakness in Internal Control over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform procurement standards to sections 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions to be included in contracts if criteria are applicable. Additionally, 2 CFR 200.214 requires recipients to restrict the subawards and contract with certain parties that are debarred, suspended, or excluded from ineligible participation in Federal assistance programs or activities. Condition: Testing of procurement activities and related controls identified the following exceptions: • The Cooperative's documented procurement policy did not include several elements required by Uniform Guidance. • One contract tested did not contain all applicable Uniform Guidance contract provisions. • In one instance involving a contract exceeding $25,000, the Cooperative did not document a review to verify that the vendor was not suspended or debarred from participation in federal programs. Cause: The Cooperative had not established procedures to periodically evaluate its procurement policy and procurement documentation for compliance with Uniform Guidance requirements, including required contract provisions, documentation of procurement decisions, and suspension and debarment verification procedures. Effect: Failure to maintain effective controls over procurement activities increases the risk of noncompliance with federal procurement requirements. As a result, the Cooperative may enter into contracts that do not contain required federal provisions, fail to adequately document procurement decisions, or engage in covered transactions with vendors that are suspended or debarred from participation in federally funded programs. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: No Recommendation: We recommend that the Cooperative update its procurement policy to incorporate all applicable Uniform Guidance requirements. Management should also establish and implement procedures to: • Verify and document suspension and debarment reviews for all applicable covered transactions. • Review contracts prior to execution to ensure all required Uniform Guidance contract provisions are included. • Maintain documentation evidencing compliance with federal procurement requirements. Views of Responsible Officials: Management agrees with the finding.

Finding 2025-001 –Procurement , Suspension & Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to the procurement standards in sections 200.317 through 200.327. These standards generally require recipients to maintain records sufficient to detail the history of procurement, including the rationale for the procurement method, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Testing of the federal program identified the following: • The Organization failed to document price comparisons including the rationale or circumstances leading up to the selection of the non-competitive sole source procurement. The Organization did follow through with the suspension and debarment check of the contracted vendor. Cause: The Organization lacked adequate documentation of procurement decisions being reached during the initial project funding phase. Effect/Potential Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Organization would be noncompliant with the compliance requirements outlined above. Questioned Costs: None reported. Context / Sampling: A statistical sample of 1 out of 3 vendors selected for testing.

Criteria - Under 2 CFR § 200.318(a), a recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for the acquisition of property or services. The documented procurement procedures must be consistent with applicable state, local, and tribal laws and regulations and with the procurement standards identified in 2 CFR §§ 200.317 through 200.327. The Uniform Guidance procurement compliance requirement also contemplates that recipients establish and follow written procurement procedures that conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200.9. Condition - During our audit of the Clean Water State Revolving Fund program for the year ended December 31, 2025, we noted that the Authority had informal procurement practices in place for purchases charged to Federal awards; however, the Authority did not maintain formal written procurement procedures applicable to procurement transactions under a Federal award or subaward. Cause - Management indicated that the Authority historically relied on informal procurement practices and institutional knowledge of staff responsible for purchasing activities. The Authority had not developed and formally approved written procurement procedures specifically addressing the Uniform Guidance procurement standards applicable to Federal awards. Effect or Potential Effect - Without documented procurement procedures, there is an increased risk that procurement transactions under a Federal award or subaward may not be performed consistently or in accordance with applicable procurement requirements. The absence of written procedures also increases the risk that personnel responsible for procurement may not consistently apply required procurement methods, obtain appropriate competition, document contractor selection decisions, perform required suspension and debarment checks, or retain sufficient documentation to support compliance. Although no questioned costs were identified as a result of the procedures performed, the lack of documented procedures represents a deficiency in the design of internal control over compliance because informal practices and reliance on external engineer review alone do not provide formal, consistent internal guidance to ensure ongoing compliance with Federal procurement requirements. Questioned Costs - None identified Recommendation - We recommend that management develop, formally approve, and implement written procurement procedures that comply with the Uniform Guidance procurement standards in 2 CFR §§ 200.317 through 200.327. At a minimum, the written procedures should address: • Procurement methods and applicable dollar thresholds; • Requirements for full and open competition; • Required approvals before procurement transactions are initiated or awarded; • Documentation requirements supporting the history of each procurement transaction;• Standards of conduct and conflict-of-interest requirements for employees involved in procurement decisions; • Procedures for verifying suspension and debarment status, when applicable; • Requirements for cost or price analysis, when applicable; • Contractor selection and contract administration procedures; • Record retention requirements; and • Monitoring procedures to ensure the written procurement procedures are consistently followed.