Findings Citing § 200.329

2025-002 Program: Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Passed-Through: Douglas County Award No. and Year: Multiple Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires non-Federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the federal award (§200.303). In addition, 2 CFR §200.328 and §200.329 require non‑Federal entities and subrecipients to submit financial and performance reports in accordance with the terms and conditions of the federal award and pass‑through entity requirements. Condition: The Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Specifically, the Town did not maintain written procedures or standardized documentation evidencing the preparation, review, approval, and submission of required special reports in the format prescribed by the pass‑through entity. Cause: Management relied on email correspondence and progress meetings rather than a formally designed and implemented reporting control process. Effect: As a result, there is a reasonable possibility that required special reporting information submitted to the County could be incomplete, inconsistent, untimely, or not retained in accordance with federal and pass‑through entity record retention requirements, without detection by management. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used as the population was too small to sample. Program reporting requirements were expenditures and amounts passed through to subrecipients were reconciled to the supporting records. Repeat Findings from Prior Years: No. Recommendation: The Town should establish and document internal controls over compliance with special reporting requirements for federal awards, including: • Formal procedures for preparing special reports in the format required by the pass‑through entity; • Management review and approval of reports prior to submission; and • Retention of complete and accurate reporting documentation in accordance with federal and pass‑through entity requirements. Views of Responsible Officials: See separately issued Corrective Action Plan.

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.

The EPA assistance agreement, in accordance with 2 CFR 200.328, required the recipient to submit semi-annual progress reports and an annual financial report by the dates specified in the award. Recipients must use the standard financial reporting forms or such other forms as may be authorized by OMB (approval is indicated by an OMB paperwork control number on the form) 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. If the Federal awarding agency requires reporting of accrual information and the recipient’s accounting records are not normally maintained on the accrual basis, the recipient is not required to convert its accounting system to an accrual basis but may develop such accrual information through analysis of available documentation. The Federal awarding agency may accept identical information from the recipient in machine-readable format, computer printouts, or electronic outputs in lieu of closed formats or on paper. The standard financial reporting forms for grants and cooperative agreements are as follows: - Federal Financial Report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Recipients use the FFR as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status (lines 10.a, 10.b, and 10c). References to this report include its applicability as both an expenditure and a cash status report unless otherwise indicated. The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period (2 CFR 200.328(c). Performance and Special Reporting Non-Federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR 200.329(c)(1)). They also may be required to submit special reports as required by the terms and conditions of the Federal award. Per the conditions of the award, the City was required to submit semi-annual progress reports and an annual financial report. During the audit period, the City did not submit the first progress report on time and the second report was not submitted. We also found that the financial report was submitted outside of the 90 day time period in which it should have been submitted. The City should implement additional procedures to ensure compliance with federal reporting requirements.

Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Passed-Through: Douglas County Award No. and Year: Multiple Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires non-Federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the federal award (§200.303). In addition, 2 CFR §200.328 and §200.329 require non‑Federal entities and subrecipients to submit financial and performancereports in accordance with the terms and conditions of the federal award and pass‑through entityrequirements. Condition: The Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Specifically, the Town did not maintain written procedures or standardized documentation evidencing the preparation, review, approval, and submission of required special reports in the format prescribed by the pass‑through entity. Cause: Management relied on email correspondence and progress meetings rather than a formally designed and implemented reporting control process. Effect: As a result, there is a reasonable possibility that required special reporting information submitted to the County could be incomplete, inconsistent, untimely, or not retained in accordance with federal and pass‑through entity record retention requirements, without detection by management. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used as the population was too small to sample. Program reporting requirements were expenditures and amounts passed through to subrecipients were reconciled to the supporting records. Repeat Findings from Prior Years: No. Recommendation: The Town should establish and document internal controls over compliance with special reporting requirements for federal awards, including: •Formal procedures for preparing special reports in the format required by thepass‑through entity; •Management review and approval of reports prior to submission; and •Retention of complete and accurate reporting documentation in accordance with federaland pass‑through entity requirements. Views of Responsible Officials: See separately issued Corrective Action Plan.

2 CFR § 1000.1 gives regulatory effect to the Department of Treasury for 2 CFR § 200.329 to require recipients of the COVID-19 Emergency Rental Assistance 2 (ERA2) grant to monitor program performance and submit quarterly reports comparing actual accomplishments to federal goals. Recipients must track expenditures, housing stability services, and household assistance data, through the Treasury's Portal via the ERA Compliance Report.Due to insufficient controls over the reporting, the City failed to submit the 2025 first and second quarter ERA Compliance Reports to the Department of Treasury. Failure to properly complete required reports could result in the loss of grant monies in future periods. The City should ensure control procedures over the reporting of information to federal grantors are in place and followed by the appropriate personnel to ensure the timely submission of required reports.

U.S. Department of Commerce Federal Financial Assistance Listing 11.307 Economic Adjustment Assistance Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.328 and 200.329 require that the auditee submit financial and performance reports for federal awards that provide accurate, current, and complete information regarding the use of federal funds. Condition: During our testing, we noted that the amounts reported on the SF-425 and SF-271 reports did not accurately reflect qualified expenditures for the year ended December 31, 2025. Cause: The entity did not have sufficient internal controls over grant reporting to ensure that reported amounts were accurate for the year ended December 31, 2025. This resulted in inaccuracies that were not identified prior to submission. Effect: The financial reports submitted to the federal agency were materially misstated and did not comply with Uniform Guidance reporting requirements. The lack of effective internal controls over grant reporting allowed these material misstatements to occur and not be detected prior to submission, which could adversely affect federal oversight, monitoring, and funding decisions. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of one SF-425 report, three SF-271 reports, and two quarterly progress reports out of a population of twelve total reports was selected for testing. Errors were noted on the SF-425 report and one of the SF-271 reports. Repeat Finding from Prior Year(s): No Recommendation: We recommend that the entity strengthen internal controls over reporting to ensure that reported amounts accurately reflect qualified expenditures for the period and comply with federal program requirements. Views of Responsible Officials: Management agrees with the finding.

FINDING 2025-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting 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): 72270 Pass-Through Entity: Indiana Department of Health Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The Town's Fire Department (Fire Department) was awarded the Health Issues and Challenges Grant through the Indiana Department of Health (IDOH), financed through the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. The grant was funded through the American Rescue Plan Act that focused on community paramedicine. Metrics and Evaluation of Funded Activities Report The Fire Department was required to submit program specific metrics and funded activities report to the IDOH through the RedCap software on a monthly basis, due 15 days after month end. The Fire Department Office Manager (Office Manager) was responsible for tracking and compiling the necessary information for the monthly reports. Of the 12 reports tested, two reports were submitted 41 and 12 days late. In addition, the monthly reports were submitted by the Office Manager via the RedCap software without a documented oversight, review, or approval process to ensure timely submission. Annual Report on Program Activities The Fire Department was required to submit an annual report on program activities to the IDOH through an infographic report. The Office Manager was responsible for tracking and compiling the necessary information for the annual report on program activities. The annual report on program activities was submitted by the Office Manager, without a documented oversight, review, or approval process to ensure timely submission. INDIANA STATE BOARD OF ACCOUNTS 18 TOWN OF CLARKSVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.329(c)(1) states in part: "The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. . . ." Cause The issues with the monthly Metrics and Evaluation of Funded Activities Reports and the Annual Report on program activities reporting processes stem from the lack of a formal oversight and review procedure to ensure accuracy and timeliness. Without a structured verification process before submission, potential errors and inconsistencies could go undetected, thus increasing the likelihood of inaccurate data reporting. Additionally, the reliance on individual staff members to compile and submit reports without secondary review created inefficiencies and contributed to delays, as evidenced by the late submission of two monthly reports. Effect The lack of oversight and review of the metrics and evaluation of funded activities reports and the annual report on program activities reporting process could result in increased risk of inaccurate data being reported to the IDOH, which could compromise the integrity of the program's performance metrics. The absence of a structed verification process can also lead to inefficiencies, as error or inconsistencies may have required corrections after submission, resulting in inefficient use of time and resources. Additionally, the late submission of two monthly reports indicated a failure to meet reporting deadlines, which could negatively impact compliance with grant requirements and potentially jeopardize future funding opportunities. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 19 TOWN OF CLARKSVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended the Fire Department implement a formal oversight and review process for all data submissions to ensure accuracy and completeness before they are submitted to the IDOH. This would involve a secondary review by a designated individual or team to verify the data. Additionally, improving workflow coordination through clearly defined roles and responsibilities for each team member would help streamline the process and prevent delays. To further improve timeliness, the Fire Department should implement a tracking and reminder system for report due dates to ensure timely submissions. Providing staff with thorough training on reporting protocols and maintaining detailed documentation will help ensure consistent adherence to procedures. Finally, establishing accountability measures through clear roles, deadlines, and regular audits would enhance the efficiency and effectiveness of the reporting process. These steps will help ensure the Fire Department meets grant requirements, maintains data accuracy, and avoids potential delays or issues in future submissions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Criteria The grant terms and 2 CFR § 200.329 require recipients to submit performance reports in the form, frequency, and timeframe established by the federal awarding agency. Reports should accurately describe program accomplishments, progress toward established objectives, reasons for delays, and relevant financial or project information. Condition Performance reports submitted to the U.S. Environmental Protection Agency (“EPA”) for the period under audit were not accurate and required multiple revisions. The EPA notified the Town that it was not in compliance with the grant terms until a correct report was submitted. In addition, the Town did not have written procedures to identify, track, prepare, review, and submit required performance reports. Instead, the Town relied on reminders from EPA regarding reporting deadlines and requirements. Cause The Town had not established formal grant-reporting procedures for this program or assigned sufficient oversight to ensure that responsible personnel understood the reporting requirements and verified reports against the grant agreement, approved workplan, and supporting records before submission. Effect The Town was not in compliance with the grant’s reporting requirements until corrected reports were submitted. The absence of procedures also increases the risk that future reports will be inaccurate, incomplete, or submitted late, which could delay grant actions or result in other federal remedies. Questioned Costs Unknown Recommendation We recommend that the Town establish written procedures for federal performance reporting that include a reporting calendar, assigned responsibilities, supervisory review, verification against grant and financial records, timely submission, and retention of documentation demonstrating federal acceptance. Views of Responsible Officials Management agrees with this finding. Community Development will establish written procedures for federal performance reporting that includes a reporting calendar, assigned responsibilities, supervisory review, verification against grant and financial records, timely submission and retention of documentation demonstrating federal acceptance.

2025-002 Improve Controls Over Reporting Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement 2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal awarding agency or pass-through entity in a timely manner as specified in the terms and conditions of the award. Program guidance for the Child Care and Development Block Grant requires that quarterly project progress reports be submitted by specified deadlines unless a formal extension is granted by the awarding agency. Condition and Context During our audit, we tested a sample of quarterly project progress reports under the Child Care and Development Block Grant. The Organization submitted one quarterly project progress reports after the required submission deadline. There was no documentation of a formal extension granted by the awarding agency. Cause The Organization’s internal controls did not ensure timely preparation and submission of required performance reports in accordance with federal program requirements, or ensure that an extension was requested. Effect or Potential Effect Late submission of required reports increases the risk of noncompliance with federal award requirements and may negatively affect the Organization’s ability to demonstrate progress on program objectives. No questioned costs are reported as the requirement is procedural in nature. Recommendation The Organization should implement procedures to ensure that all required performance reports are submitted timely in accordance with federal program requirements and have policies in place regarding formal documentation and approval of extension requests. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Reporting – Financial and Performance Assistance Listing Number 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants U.S. Department of Housing and Urban Development (HUD) Federal Award Identification Number(s): B-22-CP-CO-0165 and B-23-CP-CO-0280 Award Year – 2022 and 2023 Criteria or specific requirement: 2 CFR §§200.328 and 200.329 require recipients to submit timely financial and performance reports that are supported by underlying records and accurately reflect financial activity and program accomplishments. In addition, the grant agreement requires the grantee to submit a combined semiannual performance and financial report in the Disaster Recovery Grant Reporting (DRGR) system. The report must include a narrative describing accomplishments during the reporting period and must be submitted within 30 calendar days after the end of each six-month reporting period. Condition: During testing, we noted that the semiannual performance reports required to be submitted during calendar year 2025 were not submitted by the required deadlines. The reports, which were due in January 2025 and July 2025, were not submitted until September 2025. As a result, the Grantee did not submit required financial and performance reports within the timeframe prescribed by the grant agreement and 2 CFR §§ 200.328 and 200.329. Additionally, management could not provide evidence of review for one of the reports. Cause: Management was not aware of the semiannual reporting deadlines established by the grant agreement and did not maintain a process to track reporting due dates. As a result, required reports were not submitted within the prescribed timeframes. In addition, the documentation pertaining to the evidence of reviews and the evidence of report submission was not retained. Effect: Failure to submit required financial and performance reports timely reduced the ability of the federal awarding agency to monitor grant activities, evaluate program progress, and ensure compliance with award requirements. In addition, because the federal grant system does not permit drawdowns when required reports are overdue, the delayed submissions prevented the City from requesting reimbursement of eligible grant expenditures on a timely basis, which could adversely affect cash flow and delay project activities funded by the grant. The lack of retained review documentation prevents management from demonstrating that required reviews were performed and increases the risk that errors, omissions, or noncompliance may not be identified and corrected timely. Questioned Costs: None Context: We tested 2 of 4 required semiannual reports and found both were submitted late. A non-statistical sampling methodology was used to select the sample. Identification of a repeat finding, if applicable: N/A Recommendation: We recommend management establish and maintain a formal grant compliance tracking process that identifies all required financial and performance reports, their due dates, and responsible personnel. Management should monitor the tracking schedule throughout the year and implement reminder and review procedures to help ensure all required reports are submitted accurately and timely in accordance with federal requirements and the terms and conditions of the grant award. Additionally, management should retain documentation evidencing the review of reports and supporting records, including the reviewer and date of review, to demonstrate compliance with established review procedures. Views of responsible officials and planned corrective actions: Agree. See separate corrective action plan.

Finding 2025-003: Subrecipient Monitoring and Management 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 200.331 through 200.333; 2 CFR 200.329; 2 CFR 200.303 A pass-through entity must document subrecipient-versus-contractor determinations, verify that potential subrecipients are not excluded or disqualified, include required Federal information and conditions in subawards, evaluate risk of noncompliance, and monitor activities as necessary. Monitoring includes reviewing financial and performance reports, following up on deficiencies, and issuing management decisions for applicable audit findings. Procedures and specific conditions should respond to assessed risk. Condition: Internews Network could not provide complete documentation for several subrecipients tested. Missing items included classification, risk assessment, exclusion verification, complete agreement and award data, financial and programmatic reports and review evidence. We therefore could not determine whether risk was assessed, requirements communicated, performance and compliance monitored and issues resolved. Cause: Significant reductions in program, grants, and finance personnel followed termination of Federal awards and funding. Files and responsibilities were not fully transitioned; evidence was maintained across individual mailboxes, local drives, and other locations; and no staff-exit procedure required transfer and validation of subrecipient records. Effect or Potential Effect: The absence of monitoring documentation prevented verification that subrecipients used funds for authorized purposes, achieved required performance, complied with award terms, and corrected deficiencies. Noncompliance, unsupported costs, performance issues, or audit findings may not be detected and resolved timely. Questioned Costs: Undetermined Context: Internews Network served as a pass-through entity and provided Federal funds to subrecipients responsible for carrying out portions of the Federal program. It was therefore responsible for documenting pre-award determinations, communicating Federal requirements, assessing subrecipient risk, performing responsive monitoring, following up on deficiencies, and completing closeout. Identification as a Repeat Finding, if Applicable: Not a repeat finding Recommendation: Establish a risk-based lifecycle process with primary and backup owners. Central files should include classification, exclusion verification, risk assessment, required terms and identifiers, monitoring plan, reports, review evidence, invoice testing, audit determinations, finding follow-up, management decisions, corrective actions, and closeout. Use a register to track deadlines, risks, procedures, findings, and open items. Award termination or staffing reduction should trigger formal portfolio transfer, reconciliation of open matters, preservation of records, and certification that duties and system access were reassigned.

2 CFR 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR part 200.302. 2 CFR 200.302(a) states, in part, the non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.302(b)(2) further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosures of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Additionally, the U.S. Department of the Treasury Coronavirus Local Fiscal Recovery Fund (SLFRF) Award Terms and Conditions provides that "Recipient agrees to comply with any reporting obligations established by Treasury as they relate to this award." The U.S. Department of the Treasury requires non0entitlement unit’s (NEU’s) that are allocated less than $10 million in SLRF Funding to submit an annual Project and Expenditure Report. This report is required to include project descriptions, obligations and expenditures including current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure, and other information. Due to deficiencies in the Township's internal controls over SLFRF reporting, the Township understated current period obligations, current period expenditures, and cumulative expenditures by $304,200, $786,589, and $786,589, respectively, in the annual project and expenditure report for the period of April 1, 2024 to March 31, 2025. Additionally, the Township overstated current period obligations and current period expenditures by $2,606,935 and $1,204,345, respectively, in the annual project and expenditure report for the period of April 1, 2025 to March 31, 2026. Failure to report accurate obligation and expenditure amounts could result in the Department of Treasury taking action against the Township for failure to comply with programmatic requirements. This noncompliance also resulted in the opinion over this major federal program being qualified. The Township should implement policies and procedures to review the reports prior to submission to help ensure the reports are complete and accurate.

FINDING 2025-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Allowable Costs/Cost Principles, Period of Performance 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): 2025 Compliance Requirements: Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-003. 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 applicable requirements. The City had not properly designed or implemented such a system, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. INDIANA STATE BOARD OF ACCOUNTS 21 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Prior to the receipt of direct COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF), all eligible entities were required to execute a Financial Assistance Agreement (Agreement), which included the Award Terms and Conditions that recipients must comply with in carrying out the objectives of their award. Per the Agreement, the City was responsible for the effective administration of the federal award, as well as the application of the sound management practices and administration of federal funds in a manner consistent with program objectives and terms and conditions of the award. Recipients may use the SLFRF funds for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act, as added by section 9901 of the American Rescue Plan Act of 2021. The SLFRF program provides substantial flexibility for each recipient to meet the local needs within four separate eligible use categories. Recipients may use the SLFRF funds to:  Respond to the COVID-19 public health emergency and its negative economic impacts.  Respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers of eligible employers that have eligible workers who are performing essential work.  Provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year of the recipient.  Make necessary investments in water, sewer, or broadband infrastructure. The City elected to receive the standard revenue loss allowance, allowing it to claim its total SLFRF funds allocation of $3,821,386 as revenue loss to use for government services. The allocated funds may only be used to cover costs incurred from the period beginning on March 3, 2021, and ending on December 31, 2024. Obligations for costs incurred are required to be liquidated no later than December 31, 2026. During the audit period, the City identified that it had not properly obligated its remaining unspent SLFRF funds by the required deadline. Based on guidance from its financial consultant, the City reevaluated activity recorded in its Coronavirus State and Local Fi fund and adjusted the fund to include health insurance payments that had previously been made from another City fund. These payments related to a contractual agreement executed in July 2024 for coverage from August 2024 through July 2025. Health insurance costs incurred and paid between January and July 2025 totaled $591,563. Of the total SLFRF funds balance, the City had $77,706 in funds that were properly obligated by December 31, 2024, but remained unspent. These obligated funds were reclassified to cover $77,706 of the $591,563 in health insurance costs incurred between January and July 2025, leaving $513,857 of those costs without a corresponding obligation as of the December 31, 2024 deadline. In addition, the City incurred and paid health insurance costs totaling $619,875 for the period August through December 2025, which occurred after the contractual coverage period ended. These costs also were not obligated by December 31, 2024. As a result, a total of $1,133,732 in SLFRF funds expenditures were not obligated within the required timeframe and were not paid within the period of performance. Accordingly, these costs do not meet program requirements and are considered unallowable. The City also did not have written procedures for determining the allowability of costs in accordance with subpart E of C CFR 200. The lack of internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 22 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." INDIANA STATE BOARD OF ACCOUNTS 23 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (g) Be adequately documented. . . ." 31 CFR 35.5 states in part: "(a) . . . A recipient may only use funds for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024 . . . (c) . . . A recipient must return any funds that have not been obligated by December 31, 2024, pursuant to orders placed for property and services or entry into contracts, subawards, and similar transactions that require payment other than funds in the amount reported to Treasury by April 30, 2024, as the estimate of funds that the recipient will expend to comply with a requirement under federal law or regulation or provision of the award terms and conditions to which a recipient becomes subject as a result of receiving or expending funds. A recipient must return funds obligated for a use . . . by December 31, 2024, but not expended by December 31, 2026. . . ." Cause A proper system of internal controls over the SLFRF funds expenditures was not designed by management of the City to ensure the SLFRF funds were being used appropriately. The City did not have policies and procedures in place to ensure that its SLFRF funds were properly obligated by the December 31, 2024 deadline. Effect The lack of an effective internal control system enabled material noncompliance with the Allowable Costs/Cost Principles and Period of Performance compliance requirements to occur and remain undetected. Payments made from the SLFRF funds which were not obligated as of December 31, 2024, as required by the federal grant funding resulted in payments not made in compliance with the period of performance, and, therefore, were not allowable costs. Questioned Costs We identified $1,133,732 in known questioned costs as noted above in the Condition and Context. Recommendation We recommended that management of the City establish a proper system of internal controls and develop policies and procedures to ensure that expenditures of federal awards are allowable costs and occur within the period of performance. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2025-006 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting 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): 2025 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-005. INDIANA STATE BOARD OF ACCOUNTS 26 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 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 applicable requirements. The City had not properly designed or implemented such a system, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients are required to submit an initial interim report and quarterly or annually submit Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates are based upon the type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a city with a population below 250,000 residents that was allocated less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF). As such, an annual P&E report, covering one calendar year from April 1, 2024 to March 31, 2025, was prepared and submitted by the Clerk-Treasurer to the Treasury by April 30, 2025. The P&E report data to be submitted included, but was not limited to, current period and total cumulative obligations and current period and total cumulative expenditures. We were unable to trace the annual P&E report to the City's records. The errors identified were as follows:  Total cumulative obligations were overstated by $1,133,732.  Current period obligations were understated by $97,891.  Current period expenditures were understated by $41,094.  Total cumulative expenditures were understated by $2,696. In addition, the P&E report required obligations and expenditures to be reported by project. The City completed the report utilizing total amounts for all projects. There were 11 projects appropriated using the SLFRF funds award. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 27 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds, page 13, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." Cause The City officials appropriated the entire SLFRF award funds in May 2022 and reported the entire award amount as obligated in the P&E reports completed in 2023, 2024, and 2025. City officials were not aware that appropriating the funds alone does not constitute obligations of the award. Additionally, correcting adjustments made after the report was submitted partially contributed to the differences noted in expenditures. City officials were also not aware that obligations and expenditures could not be reported in total but should be reported by project. Effect Without a proper system of internal controls in place that operated effectively, the City did not file an accurate annual P&E report as required under the federal award. As such, the City did not accurately report current period obligations, current period expenditures, cumulative obligations, and cumulative expenditures when filing the P&E report for the period April 1, 2024 to March 31, 2025. As a result, material noncompliance occurred and remained undetected. Noncompliance with the provisions of federal statues, 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's management establish a proper system of internal controls and develop and implement reporting policies and procedures to ensure that all required reports are completed and accurate when submitted. INDIANA STATE BOARD OF ACCOUNTS 28 CITY OF VINCENNES SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 29

2 CFR 1000.10 provides that, except for the deviations set forth elsewhere in this Part, the Department of Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR part 200. 2 CFR 200.302(b)(2) further states, in part, the financial management system of each non-Federal entity must provide for accurate, current, and complete disclosures of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. 31 CFR § 35.4(c) requires, in part, that during the period of performance, recipients shall provide periodic reports providing detailed accounting of the uses of funds. Additionally, the U.S. Department of the Treasury Coronavirus Local Fiscal Recovery Fund (SLFRF) Award Terms and Conditions, Section 3, provides that "Recipient agrees to comply with any reporting obligations established by Treasury as they relate to this award." The U.S. Department of the Treasury requires non-entitlement unit’s (NEU’s) that are allocated less than $10 million in SLRF Funding to submit an annual Project and Expenditure Report. This report is required to include project descriptions, obligations and expenditures including current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure, and other information. Due to deficiencies in the City's internal controls over SLFRF reporting, the City understated current period obligations by $82,787 in the annual project and expenditure report for the period of April 1, 2024 to March 31, 2025. Additionally, the City overstated current period obligations by $1,399,323 and understated current period expenditures by $1,389,245 in the annual project and expenditure report for the period of April 1, 2025 to March 31, 2026. Failure to prepare and submit accurate reports for all required data elements, including obligation and expenditure amounts, could result in the Department of Treasury taking action against the City for failure to comply with programmatic requirements, such as eliminating or reducing future grant funding or imposing penalties. This noncompliance also resulted in the opinion over this major federal program being qualified. The City should establish and implement policies and procedures to review the reports prior to submission to ensure the reports are accurate, current and complete.

Federal Program Information: Community Development Block Grant Cluster Entitlement/Special Grants - Community Development Block Grants/Entitlement Grants AL # 14.218 Criteria: 2 CFR 200.329 and the terms and conditions of the federal award requires the entity to submit reports quarterly and timely. Condition: The quarterly reports were not submitted timely within the required time period. Questioned Costs: None Context: The quarterly reports tested were not submitted within the required 30 calendar days after the reporting period. Cause/Effect: The City failed to submit the quarterly reports timely. Repeat Finding from Prior Audit?: No Recommendation: We recommend review of current practices and implement policies establishing monitoring procedures related to reports. Management Response: To correct this deficiency and ensure timely reporting, the Community Development Division Manager has transferred the reconciliation and report preparation to the Community Development Grant Administrator, who will begin submitting reports for Q2 2026 (4/1-6/30/26). Additional measures that have been implemented include cross-training with project management staff to ensure multiple staff have the ability to submit quarterly reports, as well as the implementation of a Division-wide calendar with all reporting dates and submission requirements documented in annual reminders that each team member receives at the 30-15-1 day reminder marks prior to the final due date.

Noncompliance with Approved Federal Award Budgets and Material Weakness in Internal Control Over Compliance Assistance Listing Number: 14.251 Name of Federal Program or Cluster: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Name of Federal Agency: Department of Housing and Urban Development (HUD) Name of Pass-Through Entities: N/A Assistance Listing Number: 47.084 Name of Federal Program or Cluster: Technology, Innovation, and Partnerships Name of Federal Agency: National Science Foundation Name of Pass-Through Entities: Current Innovation Activities Allowed or Unallowed 2 CFR§200.308 revision of budget and program plans: The Code of Federal Regulations (CFR) Section 200.308(b) Deviations from Approved Budget requires the recipient or subrecipient must report deviations from the approved budget, project or program scope, or objectives(s) in accordance with §200.329. The recipient or subrecipient must request prior approvals from the Federal agency or pass-through entity for budget and program plan revisions in accordance with this section. 2 CFR§200.308(f)(9) transferring funds between construction and non-construction work under a Federal award is a revision requiring prior approval. Article 3C of the HUD Grant Agreement states all changes to the Grantee’s Project of Approved budget must be made in accordance with 2 CFR 200.308 and this grant agreement. To request HUD’s approval for a change in the project or approved budget, the grantee must submit a formal letter to the Director of HUD’s Office of Economic Development – Congressional Grants Division. The letter must be submitted by email to the assigned grant officer and must provide justification for the change. Section G.1 of the Current Innovation Grant Agreement requires prior approvals for (d) to change or temporarily replace key project staff (e) any rebudgeting in excess of 15% or $100,000, whichever is greater, by programmatic core functions, and (f) to add a line item to the budget. 2 CFR§200.303 requires the Organization to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The HUD approved line-item budget included: $140,000 Equipment: training equipment for training bays includes a virtual welder, a virtual CDL training system, and several VR training apparatuses. WRTP did not use the HUD Federal grant funds to purchase the VR training system and instead the VR training system was purchased using other grant funding. The total $1,500,000 HUD award was spent and WRTP deviated from the budget without meeting the requirements noted in the criteria section of the finding resulting in a $140,000 questioned cost. The HUD grant agreement explicitly incorporated the requirements in the Criteria section into the grant award. The Current Innovation approved budget included personnel salaries and wages for the President & CEO, Chief Operating Officer, the Program Coordinator, and Outreach Coordinator. On the December 2025 invoice sent to Current Innovation for cost reimbursement, WRTP included the salaries and wages for a total of 11 positions and some of these positions were not included in the approved budget. WRTP was working with Current Innovation to modify the budget to include additional positions but the budget modification was not approved at the time these costs were billed resulting in a $18,992 questioned cost. Management did not monitor to ensure that the requirements listed in the Uniform Guidance as well as the approved award budgets were being followed. WRTP may have expended grant funds on activities or cost categories inconsistent with the approved award budget and contract terms. We recommend that WRTP management monitor their compliance with the approved budget. If changes to the approved budget are necessary we recommend that WRTP follows the Uniform Guidance and grant agreement requirements.No Management concurs with the finding and acknowledges the importance of maintaining complete documentation supporting approved grant budgets and budget modifications associated with federally funded programs. Although the Organization monitored expenditures and program performance throughout the grant period, certain documentation supporting budget approvals and modifications was not maintained in a manner sufficient to satisfy audit requirements. During 2026, management will strengthen grant management procedures by implementing centralized grant files containing all award documents, approved budgets, amendments, correspondence, supporting approvals, and related grant documentation. Additional internal review procedures will be established to ensure budget revisions and approvals are properly documented, reviewed, and retained in accordance with grant requirements. The planned hiring of a Finance Director will provide additional oversight of grant budgeting, financial reporting, and compliance monitoring. The Finance Director will be responsible for budget development and monitoring, grant financial management, maintenance of supporting grant documentation, implementation of internal controls, development of financial policies and procedures, audit coordination, and ensuring that grant budgets, amendments, approvals, and related documentation are properly maintained and consistently applied across all funding sources. Management is committed to enhancing grant administration and compliance processes and believes the corrective actions being implemented will mitigate the risk of similar findings in future audits.

2 C.F.R. Subpart E § 200.302(b)(2) requires that entities must present accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements in §§ 200.328 and 200.329. 31 CFR § 35.4(c) further states in part that during the period of performance, recipients shall provide periodic reports providing detailed accounting of the uses of funds. The State and Local Fiscal Recovery Funds (SLFRF) annual Project and Expenditure Report requires quantifiable objective criteria containing reported obligations and expenditures for the following Key Line Items: a. Current period obligation b. Cumulative obligation c. Current period expenditure d. Cumulative expenditure The Current Period Expenditures for the Health Department / Records Center / Coroner / GIG Loan on the County's submitted SLFRF Project and Expenditure Report for the grant period ending December 31, 2025 were overstated by $1,059,739. This was due to expenditures paid for using interest revenue were improperly reported as SLFRF grant expenditures in quarter 4. All other amounts were properly reported. Failure to complete and submit accurate reports for required data elements could result in the loss or reduction of future grant funding or penalties imposed by the federal agency. The County should establish and implement procedures to review reports submitted to the federal grantor before submission to ensure that all amounts are reported correctly.

Finding reference number: 2025-002 Assistance Listing (Federal award identification number and year): Community Development Block Grants, Assistance Listing. No. 14.218 Auditor non-compliance code: N. Special Tests and Provisions Finding resolutions status: In Process. Universe population size: The universe population size is not applicable to the finding. Sample size population: The sample size information is not applicable to the finding. Statistically valid sample: Not applicable. Name of federal agency: U.S Department of Housing and Urban Development Pass-through entity: City of Detroit Questioned costs: $0 Statement of condition #2025-002: For the year ended December 31, 2025, the Corporation did not submit the Annual Reports to the City of Detroit in the time period required by Uniform Guidance. Criteria: Pursuant to 2 CFR 200.329, annual performance reports are required to be submitted to the pass-through entity (City of Detroit) no later than 90 calendar days after the end of the reporting period. Effect: The Corporation is not in compliance with Uniform Guidance performance reporting requirements. Late reporting may jeopardize future program funding or lead to increased oversight from pass-through agencies. Cause: A temporary tracking oversight during a transition between third-party property management agents left Corporation personnel initially unaware of the specific annual reporting requirement. Once the requirement was recognized, the Corporation’s efforts to submit the outstanding packages were further delayed by external administrative barriers, as the City of Detroit’s reporting portal was defunct and unassigned following the property management transition, preventing immediate subrecipient transmission. Recommendation: The Corporation should submit the required Annual Reports to the City of Detroit immediately and establish internal tracking systems to ensure all future reporting deadlines are met within the required 90-day timeframe. Management's response: Management concurs. Management has initiated outreach with the City of Detroit to resolve portal setup delays and will submit the 2025 annual reporting packages once portal access is granted. Management is also implementing internal review procedures to meet all reporting deadlines prospectively.

Criteria or specific requirement: 2 CFR Section 200.329(b) requires the entity to submit performance reports with the applicable information no less than quarterly. Condition: 2 out of 2 quarterly reports sampled were not submitted. Questioned costs: None. Context: During our testing of reporting, 2 out of the 2 quarterly reports sampled were submitted. Cause: Policies and procedures are not in place to ensure reports are submitted. Effect: Required performance report not submitted. Repeat finding: Yes. Recommendation: We recommend the organization create and or update policies and procedures to ensure all required reports are submitted timely and accurately. Views of responsible officials: There is no disagreement with the audit finding.|

Significant Deficiency in Internal Control over Compliance Federal Agency: U.S. Department of Justice Federal Program: Crime Victim Assistance Assistance Listing Number: 16.575 Direct Award Number: Not applicable Pass-Through Entity: California Governor's Office of Emergency Services (CalOES) Grant Identifying Numbers: XD-23-02-1199, AT-23-04-1199, XL-23-03-1199 Compliance Requirements: Cash Management and Reporting Criteria: Pursuant to 2 CFR §200.303, the Organization is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under 2 CFR §200.328 (financial reporting) and §200.329 (performance reporting) recipients are responsible for monitoring activities under federal awards and must submit required performance and financial reports at the intervals required by the federal award, which may be no more frequent than quarterly and no less frequent than annually. Condition and Context: The pass-through entity changed requirements in January 2025 to require only one signature/certification when they moved to electronic submission of monthly cost reimbursement claims and financial reports from paper submission that required two reviewer signatures. This caused the organization to not have proof of review by way of second signature on file for the submitted financial claims and financial reports although procedurally there was evidence of internal review within the accounting department. Cause: Management did not design and implement documented internal controls requiring supervisory review and approval of cash management activities and federal financial reporting. Effect: The lack of documented internal controls increased the risk that errors, omissions, or noncompliance related cash management and reporting could occur and not be detected in a timely manner. Questioned Costs: Not applicable. Repeat Finding: No Recommendation: We recommend management design and implement documented review and approval controls over the applicable compliance requirements. This should include regular monitoring to ensure controls are consistently applied, and periodic internal audits to assess the effectiveness of compliance systems.Views of Responsible Officials: In January 2025, CalOES moved to an electronic submission of the monthly cost reimbursement claims form and financial reports which only allowed one signature/certification on the form. Prior to 2025, the manual submission required two signatures. Under the new electronic system, the Organization did not have proof of a supervisor review on the electronic form or internally. Since the internal policy and Federal requirements ask for supervisory approval, the Organization will amend internal processes to document supervisory approval beginning in January 2027.

Significant Deficiency in Internal Control over Compliance Federal Agency: U.S. Department of Justice Federal Program: Grants to Encourage Arrest Policies and Enforcement of Protection Orders Assistance Listing Number: 16.590 Direct Award Number: Not applicable Pass-Through Entity: Contra Costa County Employment and Human Services Grant Identifying Number: 15JOVW-22-GG-01810-ICJR Compliance Requirement: Reporting Criteria: Pursuant to 2 CFR §200.303, the Organization is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under 2 CFR §200.328 (financial reporting) and §200.329 (performance reporting) recipients are responsible for monitoring activities under federal awards and must submit required performance and financial reports at the intervals required by the federal award, which may be no more frequent than quarterly and no less frequent than annually. Condition and Context: The pass-through entity (Contra Costa County) required use of their form D-15 for the sub awardee organization. That form required only one signature for preparation and submission. As such, a second signature was not on the form as proof of review. Cause: Management did not design and implement documented internal controls requiring supervisory review and approval of federal financial reporting. Effect: The lack of documented internal controls increased the risk that errors, omissions, or noncompliance related to reporting could occur and not be detected in a timely manner. Questioned Costs: Not applicable. Repeat Finding: No Recommendation: We recommend management design and implement documented review and approval controls over the applicable compliance requirements. This should include regular monitoring to ensure controls are consistently applied, and periodic internal audits to assess the effectiveness of compliance systems.Views of Responsible Officials: The Organization is a subrecipient of this grant administered by Contra Costa County. We used one signature during 2025 for preparer and submitter of the financial reporting as has been acceptable to the Contra Costa County for acceptance and processing. Although there was evidence of internal review within the accounting department, the Organization understands the need for second review documentation. A process will be implemented beginning in January 2027 to document the second review signature.

Reporting Name of Federal Agency U.S. Department of Housing and Urban Development Pass-through the Puerto Rico Housing Finance Authority Federal Program Community Development Block Grant - Disaster Recovery Federal Award B-18-DP-72-0001 2025 Federal Award Year: 2020 Assistance Listing Number 14.228 Category Significant Deficiency and Noncompliance Compliance Requirement Reporting Criteria 2 CFR Part 200.329 (c)(i) established that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually normore frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program out comes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due nolater than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or passthrough entity may require annual reports before the anniversary dates of multiple year Federal awards. As per agreement with the Organization Part IV (b) established that the Authority shall submit regular monthly progress reports to the Puerto Rico Department of Housing (PRDOH), on the form and with the content to be specified and required by the PRDOH. The PRDOH will later notify the Authority in writing the guidelines and requirements applicable to the submittal of the monthly progress reports, and such notification shall be deemed incorporated by reference to this Agreement. As defined by PRDOH, the submission of progress reports must occur within five (5) days after the end of each month. Condition During our procedures performed to determine compliance with reporting requirements, we noted that the progress reports were not submitted on time to Puerto Rico Department of Housing (PRDOH). Cause The late submission of monthly progress reports to the Puerto Rico Department of Housing (PRDOH) resulted from weaknesses in the Entity’s reporting workflow. In some instances, the Organization submitted the required progress reports after the established deadline. Additionally, PRDOH’s reporting process requires that each monthly report be reviewed and approved before the subsequent report can be submitted. As a result, when an earlier report (e.g., January) is approved several months later (e.g., in April), the next report in sequence (e.g., February) is automatically delayed. This dependency creates a chain reaction that leads to consecutive late submissions, further contributing to the systemic nature of the issue. Effect Noncompliance with the reporting requirements could lead to significant administrative actions by the grantor, including a reduction in the amounts to be awarded. In addition, it prevents the grantor from monitoring the performance of the program and could be interpreted as a failure to achieve program objectives Questioned Cost None Context The condition identified represents a recurring and systemic issue rather than an isolated instance. PRDOH requires the submission of twelve (12) monthly progress reports per fiscal year. For purposes of this audit, we examined the full universe of required reports and determined that several reports were submitted after the established due date. Because the entire population of required progress reports was reviewed, no sampling was performed, and the instances of noncompliance identified reflect the complete set of reporting activities for the year under audit. The prevalence of late submissions indicates weaknesses in the Entity’s reporting controls and affects PRDOH’s ability to perform timely oversight of program activities. This finding is a repeat of the prior year’s finding, reported as item 2024-002 Recommendation The Organization shall ensure effective supervision over its reporting processes to guarantee the timely preparation and submission of progress reports. It is advised that the Organization prioritize providing comprehensive training to personnel responsible for preparing, reviewing, and approving performance reports. This training should focus on equipping them with the necessary skills and knowledge to include all relevant data elements and adhere to deadlines consistently. Views of Responsible Officials Management of the Organization agrees with this finding. For details of the actions to be taken, refer to the Corrective Action Plan (CAP) section in this report. Responsible Person José Carrasquillo Delgado Finance Director

Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Reporting Material Weakness in Internal Controls 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 conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: Reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA) was not completed for 3 of the subrecipients in which pass through funds exceeded $30,000 and 1 of the subrecipients in which pass through funds exceeded $30,000 was not filed timely. Cause: There was a misunderstanding with management over reporting requirements surrounding amounts passed through to subrecipients. Effect: Not having a clear understanding of FFATA reporting requirements lead to required information not being reported. Questioned Costs: None reported. Context/Sampling: There was a total of 9 federal financial reports, of which 3 were selected for testing. There were a total of 10 FFATA reports, of which 4 were selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-004. Recommendation: We recommend that management review procedures and control processes to ensure they comply with the federal requirements noted above. Views of Responsible Officials: Management is in agreement.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing Number: 14.251 Pass-Through Agency: N/A Pass-Through Numbers: N/A Award Period: 8/13/2024 – 8/31/2032 Type of Finding: Material Weakness in Internal Control over Compliance Condition: The Organization was unable to provide documentation supporting the amounts included in reimbursement requests submitted under the Federal award. In addition, there was no evidence that reimbursement requests were independently reviewed for accuracy and completeness prior to submission. Criteria: Pursuant to 2 CFR § 200.329, non-Federal entities are responsible for monitoring activities under Federal awards to ensure compliance with applicable Federal requirements and to maintain sufficient oversight of Federal award operations. Such oversight includes maintaining adequate documentation to support reimbursement requests submitted to the grantor and implementing appropriate review controls over those requests. Cause: The Organization has not established or implemented formal policies and procedures governing the preparation, review, approval, and retention of documentation related to Federal reimbursement requests. Effect: Without adequate supporting documentation and evidence of supervisory review, the Organization cannot demonstrate that reimbursement requests were accurate, allowable, and consistent with Federal award requirements. This increases the risk of errors, unsupported costs, and noncompliance with Federal regulations. Repeat Finding: No Recommendation: We recommend that management establish and implement policies to retain proof of amounts requested for reimbursement. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing Number: 14.251 Pass-Through Agency: N/A Pass-Through Numbers: N/A Award Period: 8/13/2024 – 8/31/2032 Type of Finding: Material Weakness in Internal Control over Compliance Condition: The Organization did not maintain formal policies and procedures governing Federal grant reporting. Additionally, the Organization was unable to provide evidence that required reports were independently reviewed prior to submission or documentation demonstrating that reports were submitted within required deadlines. Criteria: Pursuant to 2 CFR § 200.329, non-Federal entities are responsible for monitoring activities under Federal awards to ensure compliance with applicable Federal requirements and performance expectations. Effective monitoring includes establishing controls over the preparation, review, submission, and retention of required financial and performance reports. Cause: The Organization has not established or implemented formal policies and procedures for the administration and oversight of Federal award reporting requirements. Effect: Without documented review and submission procedures, the Organization cannot demonstrate compliance with Federal reporting requirements, including the accuracy, completeness, and timely submission of required reports. The lack of supporting documentation also limits the Organization's ability to evidence compliance during monitoring activities or audits. Repeat Finding: No Recommendation: We recommend that management establish and implement formal policies and procedures for Federal award reporting. Such procedures should require: (1) preparation and independent review of all required reports prior to submission, (2) retention of documentation evidencing the review and approval process, and (3) maintenance of proof of submission to demonstrate compliance with reporting deadlines. Implementing these controls will strengthen oversight and provide support for compliance with Federal reporting requirements. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing Number: 14.251 Pass-Through Agency: N/A Pass-Through Numbers: N/A Award Period: 8/13/2024 – 8/31/2032 Type of Finding: Material Weakness in Internal Control over Compliance Condition: The Organization did not maintain documentation demonstrating that suspension and debarment verifications were performed for vendors receiving Federal funds. In addition, the Organization was unable to provide evidence of ongoing monitoring or procedures designed to ensure compliance with Federal suspension and debarment requirements. Criteria: Pursuant to 2 CFR § 200.329, non-Federal entities are responsible for monitoring activities under Federal awards to ensure compliance with applicable Federal requirements. This responsibility includes establishing procedures to verify that vendors and contractors receiving Federal funds are not suspended or debarred from participating in federally funded programs. Cause: The Organization has not established or implemented formal policies and procedures for monitoring vendor compliance with suspension and debarment requirements applicable to Federal awards. Effect: Without documented verification and monitoring procedures, the Organization cannot demonstrate compliance with Federal suspension and debarment requirements. As a result, there is an increased risk that Federal funds could be expended with vendors that are ineligible to participate in federally funded programs. Repeat Finding: No Recommendation: We recommend that management establish and implement formal policies and procedures requiring suspension and debarment verification for vendors receiving Federal funds. Such procedures should include documenting initial and periodic verifications, maintaining evidence of the reviews performed, and retaining records sufficient to demonstrate compliance with applicable Federal requirements. Views of responsible officials: There is no disagreement with the audit finding.

Department of Veteran Affairs FFAL #64.033, 20-SD-136-25, 10/1/2024 – 12/31/2025 VA Supportive Services for Veteran Families Program Reporting 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 conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: No review and approval processes were in place over 2 quarterly progress reports. Cause: Management did not have review procedures and processes in place over the quarterly progress reports until the quarter report ending June 30, 2025. Effect: Without review procedures and processes in place over reporting, demonstrating the program complies with laws, regulations, and other compliance requirements is difficult. Additionally, not having an oversight process over reporting could result in a reasonable possibility reports that are inaccurate or incomplete could be submitted. Questioned Costs: None reported Context/Sampling: Included under two award letters of the federal program, one annual financial report and 2 quarterly progress report were reviewed in the Organization’s fiscal year. In addition, two monthly HMIS reports were reviewed in the Organization’s fiscal year. There was a total of 16 reports filed. Repeat Finding from Prior Year: Yes, prior year finding 2024-003. Recommendation: Management implemented procedures and control processes to incorporate an independent review and approval over reporting effective for the quarterly progress report ending June 30, 2025. We recommend to continue following the implemented procedures and control processes and retain documentation to support the review was performed. Views of Responsible Officials: Management is in agreement.

2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.329 which provides the recipient and subrecipient are responsible for the oversight of the Federal award. The recipient and subrecipient must monitor their activities under Federal awards to ensure they are compliant with all requirements and meeting performance expectations. Monitoring by the recipient and subrecipient must cover each program, function, or activity. Grant Agreement No. B-22-CP-OH-0725 Article VI Program-Specific Reporting Requirement states that in addition to the general reporting requirements that apply under provisions of this Agreement, the following program-specific reporting requirements apply to the grantee: A. The Grantee must submit a performance report in the Disaster Recovery Grant Reporting System (DRGR) on a semi-annual basis and must include a completed Federal financial report as an attachment to each performance report in DRGR. Performance reports shall consist of a narrative of work accomplished during the reporting period. During the Period of Performance, the Grantee must submit these reports in DRGR no later than 30 calendar days after the end of the 6-month reporting period. The first of these reporting periods begins on the first of January or June (whichever occurs first) after the date this Grant Agreement is signed by HUD. B. The performance report must contain the information required for reporting program performance under 2 CFR 200.329(c)(2) and (d), including a comparison of actual accomplishments to the objectives of the Project as described in Article III, section A of this Grant Agreement, the reasons why established goals were not met, if appropriate, and additional pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs. The County submitted a semi-annual performance report for the time period ending June 30, 2025, for the Economic Development Initiative, Community Project Funding, and Miscellaneous Grants program (AL# 14.251, B-22-CP-OH-0725) indicating total funds expended of $0. The County accounting records for the time period ending June 30, 2025, had expenditures of $1,272,967, resulting in a variance of $1,272,967. The County could not provide evidence that the semi-annual performance report for the time period ending December 31, 2025, for the Economic Development Initiative, Community Project Funding, and Miscellaneous Grants program (AL# 14.251, B-22-CP-OH-0725) was submitted. Therefore, the expenditures of $2,238,372 that were spent as of December 31, 2025, were not reported. The County uploaded the semi-annual performance report for the time period ending December 31, 2025, in the DRGR system; however, the report has not been submitted by the County. The expenditures noted on this uploaded report was $0. Due to inadequate policies and procedures and insufficient controls over the reporting of semi-annual performance reports, the County failed to submit accurate amounts and the required reports. This could result in action being taken by the grantor. The County anticipates contacting HUD to amend these reporting errors. Additional controls should be implemented to help ensure accuracy of the reports.

2 CFR § 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200 for the Department of Treasury. 2 CFR § 200.302 requires, in part, recipients’ records documenting compliance to be sufficient to permit the preparation of reports required by the terms and conditions of the Federal award and Federal statutes. § 200.302 also requires recipients, in part, to provide accurate, current, and complete disclosure of financial results of each Federal award in accordance with the reporting requirements in § 200.329. 2 CFR § 200.329(c)(1) states that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR § 35.4(c) requires recipients, in part, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. The U.S. Department of Treasury provided supplementary information on reporting requirements in its interim final rule for State and Local Fiscal Recovery Funds for 31 CFR Part 35 and provided further guidance in its Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The County submitted the required SLFRF Project and Expenditure Reports; however possibly due to the failure of an existing control(s), the expenditures reported on four out of the four (one hundred percent) did not agree with the accounting records with differences ranging from ($72,289) to $2,822,608. Reporting errors could adversely affect future grant awards. An additional control(s) and/or additional procedure(s) should be implemented to help ensure accuracy of the reports.

Finding 2025-004: Reporting and Internal Controls Identification of the Federal Program - US Department of Health and Human Services, 93.778 Grants to States for Medicaid Criteria - In accordance with 2 CFR 200.329(c)(1) recipients and subrecipients must submit performance reports as required by the Federal award. In accordance with 2 CFR 200.303(a) recipients and subrecipients of Federal Awards must establish, document, and maintain effective internal controls over the Federal award that provides reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Recipients and subrecipients of federal awards must maintain evidence that such internal controls were performed. Condition - The Organization was unable to provide sufficient and appropriate evidence that reports required under the federal program were reviewed and approved by appropriate personnel prior to submission to the granting agency. Additionally, the Organization was unable to provide sufficient and appropriate evidence that one out of five selected reports was prepared and submitted as required under the federal program. Cause - Due to a lack of formal documentation of current policies and procedures, the Organization did not maintain sufficient or appropriate evidence that reviews and approvals were performed for five of the five sampled reports. Due to a lack of formal policies and procedures, the Organization did not maintain sufficient or appropriate evidence that reports submitted through the Women & Minorities portal were prepared or submitted. Effect - Reports submitted to the granting agency may be incomplete or inaccurate. Questioned Costs – None Context - Management was unable to produce sufficient and appropriate evidence that five of the five reports selected for testing were reviewed and approved prior to submission to the granting agency. For one report selected, we noted the underlying data did not reconcile to the final report submitted to the granting agency. Additionally, for one report selected, the Organization was unable to provide sufficient and appropriate evidence that the report was prepared and submitted. Repeat Finding – No Recommendation - We recommend the Organization establish formal internal controls, and documentation of their performance, relating to the review and approval of reports by appropriate personnel who is knowledgeable of such reporting requirements. Additionally, we recommend the Organization develop internal controls relating to the documentation of reports submitted through the Women & Minorities portal. View of Responsible Officials - Management will formalize the review and approval process for required federal financial reports. Reports will be reviewed by appropriate personnel knowledgeable of grant requirements, and evidence of the review will be maintained.

Reporting Federal Department – U.S. Department of Homeland Security Pass-through Illinois Emergency Management Agency Federal Award Identification Number and Year: EMW-2021-SS-00001 and 2021 EMW-2022-SS-00025-S01 and 2022 EMW-2023-SS-00013 and 2023 EMW-2024-SS-05137 and 2024 Homeland Security Grant Program, Federal Assistance Listing #97.067 County Department – Department of Emergency Management and Regional Security Finding 2025 – 004 CRITERIA As required by the 2024 grant agreement(s) with the State of Illinois, Illinois Emergency Management Agency (IEMA), Section 10.1 and 11.1, states that Grantee must submit financial and performance reports as requested and in the format required by Grantor no later than the dues date(s) specified in PART TWO or PART THREE. Grantee must submit quarterly reports with Grantor describing the expenditure(s) of the funds related thereto, unless more frequent reporting is required by the Grantee due to the funding source or pursuant to specific award conditions. 2 CFR 200.208. Any report required by 30 ILCS 708/125 may be detailed in PART TWO or PART THREE. Grantee must report to Grantor on the performance measures listed in Exhibit D, PART TWO or PART THREE at the intervals specified by Grantor, which must be no less frequent than annually and no more frequent than quarterly, unless otherwise specified in PART TWO, PART THREE, or Exhibit E pursuant to specific award conditions. For certain construction-related Awards, such reports may be exempted as identified in PART TWO or PART THREE. 2 CFR 200.329. Under Exhibit D, Performance Measures and Standards, states that the Grantee shall provide a quarterly Reimbursement Request and Reporting Form to IEMA-OHS within thirty (30) days after the end of the quarter throughout the performance period of the Agreement. The Grantee must submit a final Reimbursement Request and Reporting Form to the Grantor within 30 days after the expiration of the Agreement, or within 30 days of completion of all approved projects, whichever occurs first. Performance standards include: 1. Appropriate use of grant funds in accordance with the approved scope of work and budget outlined in Section 2.3, and the terms outlined in this Agreement; 2. The timely submittal of required documentation, as defined in this Agreement; and 3. Adequate results from grant monitoring conducted by the Grantor. CONDITION During the current audit period, Cook County Department of Emergency Management and Regional Security (DEMRS) did not comply with the reporting requirements as outlined in its grant agreement(s). CAUSE Based on discussions with management, this finding occurred due to significant turnover in key finance and grants management positions, which created gaps in continuity and delayed the Department’s transition to IEMA’s Amplifund reporting system. As prior management departed and new staff were onboarded, the Department faced operational challenges that affected the consistency of its grant reporting processes. Due to Amplifund’s requirement that reimbursement requests be submitted sequentially before performance reports can be filed, the delays in prior‑period submissions prevented DEMRS from accessing and submitting the quarterly reports. Statewide pauses in FEMA and IEMA grant processing further contributed to the backlog. EFFECT Failure to prepare and submit required reports is a violation of federal regulations and impairs the grantor agency’s ability to adequately monitor the program activities/federally funded program and could result in the loss of grant funding. QUESTIONED COSTS None. CONTEXT During the County’s fiscal year ended November 30, 2025, DEMRS had four (4) active grant agreements with IEMA, which represented a total of 16 quarterly reimbursement requests (reports) and 1 final close-out report that were required to be submitted during this period. As a result, we selected for review a total of 8 quarterly reports and the 1 final close-out report required under the 2021 IEMA grant agreement, which ended August 31, 2025. Based on discussions with management and review of the grantor payment request portal, we noted DEMRS did not submit any of the required quarterly reports due under the 2022, 2023 and 2024 grant agreements. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DEMRS develop and implement procedures to ensure required reports are prepared, reviewed, and submitted in a timely manner and in compliance with its grant agreements A compliance calendar of all future grants reporting due dates should be maintained to assist with ensuring future compliance with reporting requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 48.

Nature of Finding: Compliance Finding and Material Weakness in Internal Controls over Compliance - Reporting Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. Per the federal award agreement, specific reporting requirements with established due dates were outlined. We noted during review of the different reporting requirements that none of the reports required to be filed through September 30, 2025 were filed in a timely manner. Per the federal award agreement, the following reporting requirements were applicable through September 30, 2025: • Performance reports were required to be submitted on a semi-annual basis no later than thirty calendar days after the end of each six-month reporting period. • A written request was required to be submitted to the U.S. Department of Housing and Urban Development (HUD) no later than thirty calendar days after all grant funds were drawn down and the project was completed. Cause/Context: Controls were not in place to ensure timely reporting. Five performance reports required through September 30, 2025 were submitted late. These reports were required to be completed semi-annually subsequent to the grant agreement being signed with due dates ranging from July 2023 through July 2025, but were all filed after September 30, 2025. A written request required after project completion was also filed late as it was due thirty days following the completion of the projects but was not submitted until after September 30, 2025. The lack of controls over these reporting requirements was specific to the housing division of Hope Network and Affiliates. Effect: A lack of controls could result in late or missed reporting. Recommendation: We recommend the Network establish procedures and controls to ensure financial and performance reports are filed timely and that the Network submit all outstanding reports for the federal award. We also recommend that the Network monitor the due date of any upcoming reports, including the final closeout reports. Upon completion of the final close out report, the Network should ensure that the proper allocation of expenditures are communicated to HUD timely and accurately. Views of Responsible Officials and Planned Corrective Actions: Subsequent to September 30, 2025, the Network has filed all over-due semi-annual performance reports and submitted the required written request for confirmation of final drawdown of funds and project completion. The finance department will review all grant agreements and procedures to ensure all required reporting is tracked and filed timely according to grant documents and will develop a uniform process for existing grants across all Hope Network Affiliates.

#2025-003 – Major Federal Award Finding – Reporting Nature of Finding: Compliance Finding Reporting and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. We noted during testing of 12 different required reports, including both financial and performance reports, that 2 of these reports tested were not filed in a timely manner. Cause/Context: Controls were not in place to ensure timely reporting. Two performance reports tested were submitted one day late. Effect: A lack of controls could result in late or missed reporting. Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The Organization’s program leadership is playing a more active role in reporting and compliance and is actively involving directors of programs in the process of reporting.

Program Information: U.S. Department of the Interior Single Agreement – Assistance Listing #15.036 Award Number: A18AV00341 Award Period: 10/01/2024 – 9/30/2025 Criteria: Reporting requirements are contained in the following: Monitoring and reporting program performance, 2 CFR Section 200.329. • Per the award documents, the grantee shall prepare and provide an Annual Narrative Report. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: NWIFC did not complete and obtain management approval of the FY25 Annual Narrative Report prior to the required submission date. As a result, the FY24 Annual Narrative Report was submitted to the funding agency in its place. [ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: Internal controls were not sufficient to ensure the FY25 Annual Narrative Report was completed, reviewed, approved, and submitted in accordance with award requirements. Effect: Failure to comply with required reporting requirements may result in increased scrutiny by the funding agency and could adversely affect future funding decisions. Questioned Costs: N/A. This finding relates to reporting requirements and does not affect the allowability, support, or eligibility of program expenditures. Therefore, no questioned costs were identified. Repeat Finding: No. Recommendation: We recommend that NWIFC ensure required annual narrative reports are completed, reviewed, approved, and submitted timely, and that evidence of review and approval is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance (Scope Limitation) Federal Agency: U.S. Department of Health and Human Services Federal Program: Centers for Independent Living Assistance Listing Number: 93.432 Direct Award Numbers: 2322CAILCL-00 and 2338CAILCL-00 Pass-Through Entity: California Department of Rehabilitation Grant Identifying Number: 32594 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance – Payroll Expenditures, Cash Management and Reporting Criteria: Pursuant to 2 CFR §200.303, the Organization is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under 2 CFR §200.403 and 2 CFR §200.405, costs charged to the Federal award must be allowable, allocable, reasonable, and adequately documented. Under 2 CFR §200.403(h) and 2 CFR §200.309, costs must be incurred within the approved period of performance. Under 2 CFR §200.305, for cash management using the reimbursement method, the Organization must maintain records sufficient to support amounts requested for reimbursement and demonstrate that reimbursement requests are based on allowable program expenditures. Under 2 CFR §200.328 (financial reporting) and §200.329 (performance reporting) recipients are responsible for monitoring activities under federal awards and must submit required performance and financial reports at the intervals required by the federal award, which may be no more frequent than quarterly and no less frequent than annually. Condition and Context: The Organization did not have adequately designed internal controls over the review and approval of allowable payroll activities and payroll expenditures, cash management activities and federal reporting requirements. Specifically, there were no documented review and approval procedures or supervisory controls in place to ensure the accuracy and completeness of time and effort tracking of payroll expenditures, reimbursement requests or financial reports under the federal program. Additionally, sufficient appropriate audit evidence was not available to support compliance with the Activities Allowed or Unallowed and Allowable Costs/Cost Principles-Payroll Expenditures, Cash Management and Reporting compliance requirements. The lack of documentation and supporting records resulted in a scope limitation that prevented the auditors from performing necessary procedures to determine whether the Organization complied with applicable federal requirements related to allowed or unallowed payroll activities and allowable costs/cost principles for payroll expenditures, cash management transactions and financial reporting submissions for the population selected for testing. The condition affected the administration of the Centers for Independent Living federal program for the fiscal year ended September 30, 2025.Cause: Management did not design and implement documented internal controls requiring supervisory review and approval of allowable payroll activities and payroll expenditures, cash management activities and federal financial reporting. In addition, management did not maintain adequate supporting documentation to demonstrate compliance with federal requirements. Effect: The lack of effective internal controls increased the risk that errors, omissions, or noncompliance related to allowed or unallowed payroll activities and allowable costs/cost principles for payroll expenditures, cash management and reporting could occur and not be detected in a timely manner. Furthermore, because sufficient appropriate audit evidence was unavailable, the auditors were unable to determine whether the auditee complied with applicable federal compliance requirements related to - allowable payroll activities and payroll expenditures, cash management and reporting. Questioned Costs: Questioned costs could not be determined due to the scope limitation. Repeat Finding: No Recommendation: We recommend that management design and implement formal internal controls over - allowable payroll activities and payroll expenditures, cash management and reporting activities, including documented supervisory review and approval procedures for all time and effort tracking of payroll expenditures, federal reimbursement requests and financial reports. Management should also establish policies and procedures to ensure adequate supporting documentation is retained and readily available to support compliance with federal program requirements and facilitate audit testing. This should include comprehensive training for staff involved in federal program administration, regular monitoring to ensure controls are consistently applied, and periodic internal audits to assess the effectiveness of compliance systems. Views of Responsible Officials: Management Position: Management agrees with this finding. Adequate internal controls over payroll, cash management, and federal reporting were not in place during FY2025 as a direct result of inconsistencies in procedures and internal controls.Corrective Actions:  Accountability & Role Clarity: The Executive Director and Program Manager have mapped compliance requirements for each federal award—including expenditure review, reporting, receivables, and deliverables—and assigned clear ownership across management positions to eliminate single points of failure and reinforce segregation of duties.  Training & Ongoing Monitoring: All management staff will receive annual training on federal grant requirements (allowable/unallowable costs, period of performance, cash management, and reporting) at the start of each fiscal year. Monthly monitoring meetings among the Executive Director, Program Manager, and Accountant will precede Finance Committee meetings to review grant spending. Periodic internal reviews and a final year-end reconciliation will be conducted. Documentation & Continuity: All grant-related records will be maintained on a shared organizational drive accessible to all responsible staff. Formal onboarding and off boarding procedures for federal grant management will be developed to ensure continuity regardless of personnel changes. The Finance Manual will be updated to reflect all procedures.  Hood & Strong has been retained suggests proper internal controls necessary to achieve full federal compliance. All federal award information will be regularly reported to the Board of Directors.

Finding #2025-001: Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing: 93.243 Contract Grant Number:5H79SP082149-04 Federal Award Years: 08/31/2024 to 8/30/2025 Federal Agency: U.S. Department of Health and Human Services Criteria: Reports submitted annually by the recipient must be due no later than 90 calendar days after the reporting period in accordance with 2 CFR 200.329 C(1) and with terms and conditions of the federal award. Condition: Based on procedures performed, we identified one annual performance report was submitted six calendar days after the 90-day deadline. Questioned Costs: None Cause: Program management misunderstood the reporting deadline and process for requesting an extension resulting in the untimely submission of the annual performance report to the federal agency. No request for an extension was submitted for the report. Effect: Noncompliance with Reporting compliance requirement of the Uniform Guidance and terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend BHSST improve procedures for identification and tracking of reporting deadlines to ensure annual reports are submitted timely in accordance with the compliance requirements of Uniform Guidance, federal regulations, and terms and conditions of federal awards.

Reporting – ACF-196R Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) ALN: 93.558 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 2401TXTANF October 1, 2023 – September 30, 2024 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR §200.303(a), Health and Human Services Commission (HHSC) must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Pursuant to 45 CFR §265.3(a)(1) each State must collect on a monthly basis, and file on a quarterly basis, the data specified in the TANF Data Report and the TANF Financial Report (or, as applicable, the Territorial Financial Report). More specifically, Form ACF-196R is used by States administering the Temporary Assistance for Needy Families (TANF) program to report quarterly expenditure data and to request quarterly grant funds. The ACF-204 report (Annual Report on State Maintenance-of-Effort Programs) must be completed and submitted in accordance with the requirements at 45 CFR §265.9(c). The report includes several line items that contain critical information, including “Total State MOE Expenditures.” Input for the Total State MOE expenditures line item is provided by the Texas Education Agency (TEA), the Texas Workforce Commission (TWC), and HHSC. The MOE amounts in the ACF-204 report are to agree to the amounts in the final ACF-196R report. For the FY2024 ACF-196R report, the contributing agencies reported State MOE expenditures on various line items including but not limited to: HHSC – Line 6a (Basic Assistance (excluding Relative Foster Care Maintenance Payments and Adoption and Guardianship Subsidies) TEA – Line 11b (Pre-Kindergarten/Head Start) Condition: All key line items in the FY 2024 ACF‑204 report were tested and agreed to supporting documentation without exception. However, the Total State Maintenance of Effort (MOE) Expenditures reported in the ACF‑204 by HHSC and the Texas Education Agency (TEA) did not reconcile to the amounts reported in the ACF‑196R as shown below: Amounts reported in the ACF‑204 were accurate and supported; the variances occurred because the ACF‑196R reflected higher MOE expenditures than those reported on the ACF‑204. Questioned costs: None. Context: See “Condition.” Cause: The variance in line 11b was due to miscommunication between the relevant HHSC personnel regarding revisions to an initial submission. The variance in line 6a was due to the HHSC Federal Reporting Team incorrectly including period 1 of 2025 in the MOE calculation. The agency did not perform a complete reconciliation between the ACF‑204 and ACF‑196R prior to submission, resulting in inconsistent MOE reporting across the required reports. Effect: Inaccurate or inconsistent reporting of MOE expenditures increases the risk of noncompliance with federal reporting requirements under 2 CFR §200.302 (financial management) and 2 CFR §200.329 (performance and financial reporting). These discrepancies may impair the federal awarding agency’s ability to evaluate program performance, assess State MOE compliance, and rely on the accuracy of reported financial information. Repeat Finding: No. Recommendation: HHSC should strengthen their financial reporting controls to ensure consistency between the ACF‑204 and ACF‑196R reports. Specifically, the agency should implement a formal reconciliation process that: • Compares all MOE expenditure amounts reported on the ACF‑204 to those reported on the ACF‑196R prior to submission; • Requires documented review and approval of the reconciliation by management; and • Ensures any discrepancies are researched, resolved, and corrected before the reports are finalized. Views of responsible officials: HHSC concurs with the recommendation.

Finding Reference: 2025-002 Reporting Federal Agency: U.S. Department of Agriculture Federal Program: Water and Waste Disposal System for Rural Communities - ALN 10.760 Compliance Requirement: Reporting Criteria: The Uniform Guidance requires that non-federal entities may be required to submit performance reports at least annually but not more frequently that quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR section 200.329). They also may be required to submit special reports as required by the terms and conditions of the federal award. The U.S. Department of Agriculture requires the Authority to submi quarterly Income and Expense Statements. The reports are to be signed by the appropriate borrower official and submitted within 30 days of each quarter's end. Condition: The Authority has not submitted Quarterly Income and Expense Statements within 30 days of the fiscal quarter end. However, the Authority has submitted audited annual financial reports within 9 months of fiscal year end. This is a repeat report finding from the prior year (2024-003). Cause and Effect: The Authority was unacquainted with quarterly filing requirements as set forth by the U.S. Department of Agriculture per the loan agreement. Without filing quarterly Income and Expense Statements, USDA is unaware of how funding is spent throughout the year. Questioned Cost: None Recommendation: The Authority should begin to submit quarterly reports in accordance with loan agreement. Views of Responsible Officials: The Authority is now aware of the quarterly reporting requirements. The Authority has developed and implemented procedures to ensure that all future reports will be submitted timely.

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Federal Award Findings and Questioned Costs July 31, 2025 Comment #2025-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Agency. The preparation of these financial statements in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The close-out process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. While there has been improvements, we noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, deferred revenue, and other close-out procedures accurately and in a timely manner. This resulted in adjustments necessary to present the financial statements and disclosures of the Agency as of July 31, 2025. We also noted significant weaknesses in internal controls over payroll and recording various journal entries related to payroll transactions and fringe benefits. Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425, DHS’s reports for LIHEAP, etc.). The systemic cause appears to be the change in the accounting staff and continuing education and training in grant accounting. Policies and procedures are not up-dated and followed consistently throughout the year. Context: Review of internal control structure of the organization in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.328 Financial reporting and §200.329. (Continued) Effect: Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes. Cause: Turnover of key staff, change in the accounting system, limited personnel with knowledge and/or the ability to assist and provide needed information to aid in financial statement preparation. Recommendation: The degree to which the preparation of the financial statements and related disclosures are prepared by the independent auditor is a control deficiency as determined by the knowledge, skills and experience of those in the organization who are charged with the responsibility of its financial reporting. The Agency's chief financial officer (CFO) should require the grant accountant and a general ledger accountant to receive annual training by professionals in the field of grant accounting and reporting. The payroll clerk should receive proper training in processing journal entries for all areas of payroll. All accounting staff should have the adequate skills, knowledge and experience to oversee and/or perform the necessary accounting functions each month. Policies and procedures should be updated to adequately address the challenges and dynamics of the community action agency. We believe that the CFO with the supporting staff and general ledger accountant should have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner so as to eliminate the risk of significant errors occurring. Budget-to-actual schedules should be an integral part of the grant accountant’s basic responsibilities. Program directors should be involved in the closing process. We further recommend that training be provided to all staff engaged in the financial reporting, allocations and reconciliation functions to ensure that a complete and accurate financial statements close-out process is achieved each month and annually. Accounting policies and procedures must be updated and implemented. Views of Responsible Officials and Planned Corrective Actions: Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will require additional specialize training for fiscal staff and improve in the segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The CFO will take lead in financial reporting to ensure that all reporting meet GAAP and GAS requirements and to provide informative reports for Board and Management. All enhancements will be implemented by June 30, 2026.

Finding 2025-001: Reporting - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: CCDF Cluster, 93.575 Federal Award Identification Number and Year: 2101HICSC6, 2021 Name of Pass-through Entity: State of Hawaii Department of Human Services Criteria: According to 2 CFR 200.329, management is responsible for ensuring that all reports are submitted timely, in accordance with organizational policies and compliance requirements. Condition: During the audit we noted that the Organization had not retained documentation showing that the required reports were submitted timely. Cause: The Organization's financial management did not retain documentation indicating that the reports were submitted timely. Effect or Potential Effect: This condition may lead to non-compliance with reporting requirements. Questioned Costs: N/A Context: This issue was noted across multiple reporting instances. While management submitted complete and accurate reports, documentation confirming timely submission was not retained. Identification as a Repeat Finding: This is a repeat finding. See 2024-02. Recommendation: We recommend that the Organization implement policies, procedures, and controls to ensure that there are documented and retrievable records to indicate that reports were submitted timely. Views of Responsible Officials: Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

Strengthening Institutions Program – Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting 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 conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Section 3 of the Title III Endowment Report for the year ending June 30, 2024, was completed materially incorrect for Type of Savings Account Security line items and Total Invested line item. Cause: There was a lapse within the internal control process ensuring the report was completed materially correct. Effect: The annual report was completed materially incorrect and filed with the Department of Education. Questioned Costs: None. Context/Sampling: No sampling was utilized. The only report required to be filed in the fiscal year was tested. Repeat Finding from Prior Years: Yes. Recommendation: The University should review their current internal control process to ensure required reports are completed materially correct. Views of Responsible Officials: Management agrees with the finding.

Finding 2025-002 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Education Federal Program: Research and Development Cluster ALN: 84.351 Award Numbers: S351A210129 Award Years: 2021-2026 Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: Per 2 CFR 200.329, the grant recipient must monitor their activities under Federal Awards to ensure they are compliant with all requirements and meeting performance expectations. Per the grant award, performance reports should contain current performance and financial expenditure information for the grant. Condition and context: During our testing of reporting, we noted that the total expenditures reported on the November performance report exceeded the expenditure account detail for the reporting period by about $60,000. Per the grant director, this was due to purchase order requisitions being cancelled by the business manager that were still accrued as expenditures on the November report by the grant director. Cause: The district did not have internal controls in place to avoid overstating expenditures in the grant report. Effect: Failure to accurately report expenditures could result in noncompliance with federal grant requirements and a loss of Federal grant funding. Questioned Costs: None. Repeat Finding: No. We believe this to be an isolated occurrence. Recommendation: We recommend that the District follow internal control procedures to confirm that grant expenditures are accurately reported. Management’s Response: Management concurs with the finding. See Corrective Action Plan.

Finding 2025-003 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Education Federal Program(s): Indian Education – Tribal Leaders of Tomorrow Assistance Listing Number(s):84.299A Award Number(s): S299A200024-24 Award Years: 2024 Type of Finding: Significant deficiency in internal control over compliance and noncompliance. Criteria: All recipients are required to submit an annual Grant Performance Report providing the most current performance and financial expenditure information that is sufficient to meet the reporting requirements of 2 CFR 200.328, 200.329 and 34 CFR 75.720. Yukon Flats is required to submit quarterly performance reports within 30 days after the end of each quarter. Condition and Context: The client was unable to locate the annual report that was submitted for the program. Additionally, they were unable to show that the annual report or the quarterly reports were submitted timely. Cause: Lack of internal controls related to reporting requirements and employee turnover at the District. Effect: Lack of internal controls over reporting could allow requirements to be missed that could in turn lead to a loss of funding. Repeat Finding: This is not a repeat finding. Questioned Costs: None reported. Recommendation: We recommend that management implement stronger internal controls over reporting, specifically to retaining supporting documentation of timely submission. Management Response: Management concurs with this finding. See Corrective Action Plan.

Congressional Directives, U.S Department of Health and Human Services, Federal Assistance Listing #93.493; Contract No. 90XP0658-01-00 Condition: The amount of expenditures covered by the report period were inaccurately reported to the federal granting agency. Criteria: In compliance with Title 24 CFR Subpart D Post Federal Award Requirements §200.302 Financial management (b): The financial management system must provide for (2) Accurate, current, and complete disclosure of the financial results of each Federal award program in accordance with the reporting requirements set forth in SS 200.328 and 200.329.” Cause: The error stems from a clerical oversight related to evaluating the amount of expenditures at the wrong date, as the transactions in the final month of the reporting period had not been closed out by the Organization at the time the report was prepared. Effect: The Organization failed to report the actual amount of expenditures in accordance with the program requirements, resulting in an understatement of $85,195 on the report. Failure to submit accurate funding and financial data could result in loss of future funding. Recommendation: Management should perform an internal review over inputs into federal financial reports before they’re submitted, to verify that inputs are accurate and cover the appropriate reporting period.

Finding 2025.002 - Reporting - Material Weakness Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: Head Start Cluster, 93.600 Federal Award Identification Number and Year: 01CH011268-05-01 (2024), 01CH012890-01-01 (2024), 01CH011268-05-03 (2024) Name of Pass-through Entity (if applicable): N/A Criteria In accordance with §200.328 Financial Reporting and 200.329, Monitoring and Reporting Program Performance, recipients and subrecipients must submit financial and performance reports as required by the award. Under the requirements of the Federal Funding Accountability and Transparency Act (“FFATA”) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to identify awards subject to FFATA, collect and report information on each first tier subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition A SF-425 report was not properly supported by accounting records or reviewed prior to filing. Additionally, the Federal Funding Accountability and Transparency Act ("FFATA") report for the subrecipient was not filed. Cause CLC lacks sufficiently documented policies and procedures related to the grant's reporting requirements. CLC experienced a change in personnel. Management did not maintain supporting documentation for the SF-425 report and did not have the report reviewed prior to submission. Additionally, management was unaware of the FFATA reporting requirement. Effect or Potential Effect Inadequate documentation of policies and procedures for reporting requirements and controls over the preparation and review of reports resulted in the untimely filing of required reports causing there to be noncompliance with the reporting requirement set forth by the Uniform Guidance. Lack of review and support may result in the improper reporting of activity to the granting agency. Questioned Costs None Context One of two SF-425 reports was tested. The report tested did not have supporting documentation or evidence of review. The entity was required to submit 1 FFATA report, which was not submitted. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend that management establish and formally document comprehensive policies and procedures for the reporting process. These policies and procedures should clearly outline all required reports, filing timelines, and the method for maintaining supporting documentation. We recommend that CLC develop and implement a standardized checklist outlining all required grant compliance requirements. The checklist should clearly identify the individual responsible for preparation and the individual responsible for review. Additionally, both the preparer and reviewer should document their completion of the review to provide evidence that compliance requirements have been appropriately verified. Views of Responsible Officials Children’s Learning Centers of Fairfield County, Inc. concurs with this finding. Management will establish and formally document grant reporting policies and procedures for the Head Start Cluster, including a centralized compliance calendar, required deliverables list, and a standardized checklist for each reporting package (including SF-425 and FFATA subaward reporting, as applicable). All reports will be supported by underlying accounting records, retained in a centralized repository, and subject to documented preparer and independent reviewer sign-off prior to submission. CLC will provide staff training and cross-training to maintain continuity during personnel changes.

Congressional Directives, ALN 93.493 U.S. Department of Health and Human Services Program Year 2024 - 2025 Criteria or Specific Requirement - Reporting 2 CFR 200.329 Condition - Semi-annual performance reports submitted to the U.S. Department of Health and Human Services (HRSA) portal were not submitted timely. Cause - The University experienced uncertainty regarding the expected submission timeline for the required performance report. Effect or Potential Effect - The University submitted the performance report to HRSA after the deadline. Questioned Costs - None Context - Out of the population of two semi-annual performance reporting requirements for the fiscal year, a sample of one report was selected for testing. Our sample was not, and was not intended to be statistically valid. The performance report tested was not submitted in a timely manner. Identification as a Repeat Finding - N/A Recommendation - The University should review and update their internal controls to ensure performance reports are submitted in a timely manner.

U.S. Department of Homeland Security Direct Funding FFAL# 97.083 Staffing for Adequate Fire and Emergency Response (SAFER) Cash Management, Reporting Significant Deficiency in Internal Control Criteria: In accordance with 2 CFR 200.302, non-Federal entities must establish and maintain effective internal controls over Federal award compliance, including controls over cash management and Federal financial and performance reporting. Additionally, 2 CFR 200.327–200.329 require accurate, complete, and timely submission of performance and financial reports. Condition: The City did not have adequate internal controls to ensure the accuracy, completeness, and proper authorization of submissions to the Federal agency. Specifically: 1. Financial and performance reports submitted to the Federal agency did not undergo a secondary (independent) review prior to submission. 2. Reimbursement requests submitted to the Federal agency did not undergo a secondary (independent) review prior to submission. Cause: The City has not implemented or enforced a formalized review process that requires supervisory-level approval prior to the submission of reports or reimbursement requests. Effect: Without a secondary review, there is an increased risk that inaccurate, incomplete, or unsupported information may be submitted to the Federal agency. This could result in: • Reporting errors or omissions, • Noncompliance with Federal requirements, • Potential questioned costs, and • Increased risk of funding delays or corrective action requirements. Questioned Costs: None to report Context/Sampling: Out of a total population of three reports and reimbursement requests, three were selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend that the City design and implement formal internal controls requiring documented secondary review and approval for all financial and performance reports, and all reimbursement requests submitted to Federal agencies. Views of Responsible Officials: Agree.

Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Criteria: Award recipients, as dictated by the grant agreements, may be required to provide performance reporting to the awarding agency in order to maintain funding. For performance reporting, non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly using a form or format authorized by the awarding agency (2 CFR 200.329). Condition: In accordance with the grant agreements, the College was required to provide certain quarterly and annual performance reports which were not submitted timely. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for periodic performance reporting per the grant agreements. Effect: Certain performance reports were not submitted timely in accordance with the requirements of the respective grant agreements. Questioned Costs: None. Context: For the “Transition TA & Administration” and “Summer Transition Programs” grants, the College was unable to produce evidence that performance reporting occurred timely and with the requisite approvals. Repeat Finding: No. Recommendation: It is recommended that management perform a more thorough review of specific reporting requirements related to the ALN 84.126A grant agreements to ensure that the College’s requirements as they relate to performance reporting requirements are met. Views of Responsible Individuals: In response, the College is looking to implement a centralized reporting and tracking system with reminders for deadlines as well as incorporating reviews over performance reporting into month-end procedures. Oversight over reporting has been added as part of the monthly Research Administration meetings, and the College is looking to expand support staff to assist with performance monitoring. Lastly, the College is planning to expand annual training requirements for all principal investigators and support staff. Refer to the Corrective Action Plan for Current Year Findings.

2025-001 Report Submission Delay Program: 93.778 Medicaid Cluster – Medical Assistance Program, Pass-Through Award #567787 Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report. Condition: During our audit, we identified one quarterly status report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date. Cause: During the reporting period, the report was submitted to the COR after the stated due date due to an administrative oversight by program management. Effect: Report was not submitted to the COR in a timely manner and a request for extension of the due date was not made. Questioned Costs: None noted. Context: The report was due to the COR within 20 days of the reporting period end and was submitted one day after the stated due date. Repeat Finding: No. Recommendation: When timely submission may not be possible, Union of Pan Asian Communities should request an extension from the COR by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, Union of Pan Asian Communities should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.