Findings Citing § 200.334

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

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

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted:  For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted:  For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted:  For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted:  For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 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. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Assistance Listings number and name: 84.002 Adult Education—Basic Grants to States Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024; 24FIELCC-412421-01A, July 1, 2023 through June 30, 2024; 24FIETCO-412421-01A, July 1, 2023 through June 30, 2024; 24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024; 24FIECTC-412421-01A, July 1, 2023 through June 30, 2024 Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles Questioned costs: $52,754 Assistance Listings number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096, October 1, 2020 through September 30, 2025; P031S200281, October 1, 2020 through September 30, 2025; P031C210057, October 1, 2021 through September 30, 2026; P031C210077, October 1, 2021 through September 30, 2026; P031S220015, October 1, 2022 through September 30, 2027; P031S220179, October 1, 2022 through September 30, 2027; P031A230147, October 1, 2023 through September 30, 2028; P031S230158, October 1, 2023 through September 30, 2028 Compliance requirements: Activities allowed or unallowed Questioned costs: $20,411 Federal agency: U.S. Department of Education Total questioned costs: $73,165 Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information. Table 1 Summary of the $73,165 of payroll costs the District did not properly support or approve Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs Total employees tested 35 19 54 Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8 Total unsupported payroll costs $52,366 $9,636 $62,002 Total employee time sheets lacking approval after the work was performed2 2 12 14 Total unapproved payroll costs $388 $10,775 $11,163 Total number of employees with unsupported or unapproved payroll costs 9 13 22 Total salaries not supported $52,754 $20,411 $73,165 Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers. Table 2 Calculation of percent of payroll costs to total program expenditures Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total number of employees 279 214 Total payroll costs $3,613,133 $1,984,462 Total program costs $5,026,228 $6,696,263 % of payroll costs to total program costs 72% 30% Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required. Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions. 2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs. 3. Enforce and train employees on District written procedures and requirements to: a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor. b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated. 4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Auditor General. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf 2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee. 3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual. 5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf 6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.

Assistance Listings number and name: 84.002 Adult Education—Basic Grants to States Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024; 24FIELCC-412421-01A, July 1, 2023 through June 30, 2024; 24FIETCO-412421-01A, July 1, 2023 through June 30, 2024; 24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024; 24FIECTC-412421-01A, July 1, 2023 through June 30, 2024 Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles Questioned costs: $52,754 Assistance Listings number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096, October 1, 2020 through September 30, 2025; P031S200281, October 1, 2020 through September 30, 2025; P031C210057, October 1, 2021 through September 30, 2026; P031C210077, October 1, 2021 through September 30, 2026; P031S220015, October 1, 2022 through September 30, 2027; P031S220179, October 1, 2022 through September 30, 2027; P031A230147, October 1, 2023 through September 30, 2028; P031S230158, October 1, 2023 through September 30, 2028 Compliance requirements: Activities allowed or unallowed Questioned costs: $20,411 Federal agency: U.S. Department of Education Total questioned costs: $73,165 Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information. Table 1 Summary of the $73,165 of payroll costs the District did not properly support or approve Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs Total employees tested 35 19 54 Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8 Total unsupported payroll costs $52,366 $9,636 $62,002 Total employee time sheets lacking approval after the work was performed2 2 12 14 Total unapproved payroll costs $388 $10,775 $11,163 Total number of employees with unsupported or unapproved payroll costs 9 13 22 Total salaries not supported $52,754 $20,411 $73,165 Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers. Table 2 Calculation of percent of payroll costs to total program expenditures Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total number of employees 279 214 Total payroll costs $3,613,133 $1,984,462 Total program costs $5,026,228 $6,696,263 % of payroll costs to total program costs 72% 30% Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required. Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions. 2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs. 3. Enforce and train employees on District written procedures and requirements to: a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor. b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated. 4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Auditor General. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf 2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee. 3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual. 5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf 6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.

Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.

Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.

Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.

Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance Program Award numbers and years: 1505-0270, May 5, 2021 through September 30, 2025; 23*019, May 5, 2021 through September 30, 2025; 23*056, May 5, 2021 through September 30, 2025; 23*064, May 5, 2021 through September 30, 2025 Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation and guidance, for information it reported to the federal agency for its Emergency Rental Assistance (ERA) Program and Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programs, the County’s Grants Management and Innovation Department (Department) did not retain documentation to support 8 reports we tested and did not always report accurate information or required elements. Specifically, we found that the Department: • Did not retain documentation for 4 ERA and 4 SLFRF reports—The Department did not retain documentation, like system reports, screenshots, or queries, to support the information it reported for 4 ERA and 4 SLFRF quarterly reports we tested.1 • Did not accurately report information for 4 SLFRF reports—The Department incorrectly reported information for the 4 SLFRF quarterly reports specified in the previous bullet. Specifically, the Department understated cumulative program expenditures by nearly $14.6 million, or 10% of total cumulative program expenditures, as of June 30, 2024. • Failed to report required elements for 2 ERA reports—The Department did not report all key performance and financial reporting data points required by the federal agency in 2 of 4 ERA quarterly reports we tested, thereby limiting the amount of data we could audit. Specifically, the Department did not submit: o Demographic information for the ERA2 – Q2 2023 report due August 16, 2023. o Any performance or financial reporting data for the ERA2 – Q3 2023 report due November 15, 2023. As of June 30, 2024, the County spent $77.6 million, or 99% of the nearly $77.7 million of ERA program monies, and $147.1 million, or 72% of the over $203.4 million of SLFRF program monies, advanced in fiscal year 2021. Effect—The Department’s failure to report required elements and accurate program information in its reports and to retain associated documentation for audit purposes resulted in us being unable to determine whether the reports were complete and accurate. Also, it results in the federal agency being unable to rely on the reports to monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program’s success. Further, the Department is unable to resubmit reports because the federal agency does not allow grantees to revise reports after the reporting period has closed.2,4 Finally, the Department is at risk that this finding applies to other federal programs it administers. Cause—As described in finding 2024-103, the Department did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses. Department management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation because the Department did not have a formal policy requiring a documented review and approval of its reports. Further, the Department did not have a process to track when each report was required to be completed and did not verify that reports were submitted by the designated due dates. Additionally, Department management reported that it had significant staff turnover between fiscal years, resulting in current staff being unaware of how past reports were prepared and what supporting documentation was used. Further, Department management reported that there were many challenges in using the U.S. Department of the Treasury’s portal, including the inability to make changes to submitted reports after the reporting period ended. Criteria—Federal agency guidance requires the Department to report accurate and complete information for the ERA and SLFRF quarterly reports.3,4 Also, federal regulation and Department retention policies require the Department to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report (2 CFR §200.334).5 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Prepare and retain detailed documentation, such as system reports, screenshots, or queries, to ensure accurate and complete program information is reported to the federal agency for each federal program. 2. Follow its retention policies and procedures and federal regulation requirements to retain all records relating to a federal award for a period of 3 years from the date of its submission of the final expenditure report. 3. Develop, document, and implement policies and procedures and train responsible employees to monitor compliance with the program’s reporting requirements, including processes to: a. Reconcile expenditure amounts reported to the County’s accounting records and investigate and resolve any differences prior to submitting the reports to the federal agencies. b. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. c. Create a tracking mechanism to ensure reports are completed and submitted by the designated due dates. 4. Work with the U.S. Department of the Treasury to determine if it will require and allow the Department to adjust and resubmit previously submitted reports to correct detected errors and/or missing information. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Department did not retain documentation for the following ERA quarterly reports: ERA2 - Q2 2023, Q3 2023, Q4 2023, and Q1 2024. Further, the Department did not retain documentation for the following SLFRF quarterly Project and Expenditure Reports: April 1, 2023 through June 30, 2023; July 1, 2023 through September 30, 2023; October 1, 2023 through December 31, 2023; and January 1, 2024 through March 31, 2024. 2 On April 2, 2024, the U.S. Department of the Treasury updated its ERA2 Treasury Portal User Guide, which indicates that the grantee can only resubmit a report before the reporting deadline. (U.S. Department of the Treasury. [2024, April]. Emergency Rental Assistance Program [ERA2] Treasury Portal User Guide, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Portal-Users-Guide.pdf). 3 The U.S. Department of the Treasury requires the Department to submit accurate and complete ERA quarterly reports of cumulative programmatic and financial information covering the period from receipt of awards to the end of the current quarterly reporting period (U.S. Department of the Treasury. [2024, September]. Emergency Rental Assistance Program [ERA2] Reporting Guidance, Version 3.0. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 4 On April 7, 2023, the U.S. Department of the Treasury updated its Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, which indicates that the grantee can only resubmit a report before the reporting deadline. Further, the U.S. Department of the Treasury requires the Department to submit accurate and complete SLFRF quarterly project and expenditure reports that provide information on projects funded, expenditures, and contracts and subawards greater than or equal to $50,000, and other information required from recipients. (U.S. Department of the Treasury. [2023, April]. Project and Expenditure Report User Guide State and Local Fiscal Recovery Funds, Version 2. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/ERA2-Reporting-Guidance.pdf). 5 Pima County’s record retention schedule requires federal grant records to be retained after quarterly, annual, or final expenditure reports are submitted and approved or after funding agency requirements are met, whichever is longer (Pima County. [2023, December]. Pima County Record Retention Schedule).

Federal Program: ALN 14.218 - Community Development Block Grants/Entitlement Grants Category: Compliance/Internal control Compliance Requirement: Allowable Costs/Cost Principles Criteria: As part of the standards for documentation of personnel expenses (2 CFR §200.430 (i)), it is required that charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed and be supported by a system of internal control that ensures accuracy, allowability, and proper allocation. According to the record retention requirements (2 CFR §200.334), recipients and subrecipients are required to retain all records for three years from the date of submission of their final financial report, or from the date of submission of the respective reports if the award is renewed quarterly or annually. The federal regulations require employers to verify the identity and employment authorization of individuals hired for employment in the United States using the Employment Eligibility Verification form (I-9). The EEOC's Enforcement Guidance on Harassment in the Workplace recommends that employers periodically update their sexual harassment policies and conduct regular training to ensure compliance with federal antidiscrimination laws. 2 CFR §200.112 requires that Federal agencies establish conflict of interest policies for Federal awards. Recipients or subrecipients must disclose in writing any potential conflict of interest to the Federal agency or pass-through entity in accordance with the established Federal agency policies. Regular updates to conflict-of-interest certifications are recommended to ensure ongoing compliance. As part of the BGCPR recruitment, selection, and hiring process, it is required that the employee file includes a copy of form I-9 and a signed copy of the job description. The protocol for disclosure of conflicts of interest establishes that as part of the recruitment procedures and on an annual basis, all candidates for the board of directors, management teams, employees, and, in certain cases, investors and donors are required to complete a conflict-of-interest disclosure form. Condition: There were significant gaps in the documentation of employee files, which pose potential noncompliance risks. Cause: Lack of monitoring procedures to ascertain compliance with federal, local and internal requirements.Effect or potential effect: Failure to maintain proper documentation can result in non-compliance with federal regulations and organizational policies, potentially leading to legal penalties and ethical breaches. Questioned costs: Not determined Context: The allowable activities/cost test revealed the following: • One (1) of fifty (50) employees’ files tested did not have a copy of the Employment eligibility verification form (I- 9) • Nineteen (19) of fifty (50) employees’ files tested did not have a copy of the signed job description. • Forty-nine (49) of fifty (50) employees’ files tested did not have evidence of certification regarding compliance with conflicts of interest protocol. • Twenty-nine (29) of fifty (50) employees’ files tested did not have evidence of annual training of sexual harassment. Recommendation: We recommended that BGCPR implement comprehensive record retention policies and ensure strict adherence to established procedures. Additionally, BGCPR should establish monitoring procedures to ascertain the completeness of employee files in compliance with regulatory requirements. Views of responsible officials: BGCPR acknowledges that document retention policy does not comply with the requirements set forth in Title 2 of the Code of Federal Regulations (2 CFR §200.334). This regulation requires that all financial records, supporting documents, statistical data, and other files related to federal grants be retained for a minimum period of three years from the date of submission of the final financial report. In the absence of this policy, BGCPR exposes itself to risks of non-compliance and possible sanctions during federal audits or reviews. Therefore, it is considered a priority to develop and implement a document retention policy that ensures compliance with this regulation and strengthens institutional transparency and accountability. As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic monitoring procedures to verify record completeness and compliance. d. Implement scheduled internal reviews and standardized checklists. e. Assign specific responsibilities to Human Resources personnel for policy enforcement.

Criteria or Specific Requirement: In accordance with the grant agreements and applicable federal record retention standards (2 CFR 200.334), recipients of federal funds must maintain all records pertinent to the grant—including required progress and financial reports—for a minimum of three years from the date of submission of the final expenditure report. Condition and Context: Solvista Health did not retain certain key documents required to be retained under federal regulation and specific grant agreements. Specifically, Solvista Health was unable to provide quarterly reports, expenditure reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs. Questioned Costs: N/A Cause: Solvista Health did not implement adequate internal controls to ensure that submitted reports and expenditure reimbursement packets were archived and retained in accordance with grant and federal requirements. Effect: The absence of these records could impede the ability to verify proper grant administration and verify submitted expenditures were allowable costs incurred in accordance with the federal award agreement, which could impact future funding eligibility. It also represents a potential noncompliance with federal grant requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period.

Criteria or Specific Requirement: In accordance with the grant agreements and applicable federal record retention standards (2 CFR 200.334), recipients of federal funds must maintain all records pertinent to the grant—including required progress and financial reports—for a minimum of three years from the date of submission of the final expenditure report. Condition and Context: Solvista Health did not retain certain key documents required to be retained under federal regulation and specific grant agreements. Specifically, Solvista Health was unable to provide quarterly reports, expenditure reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs. Questioned Costs: N/A Cause: Solvista Health did not implement adequate internal controls to ensure that submitted reports and expenditure reimbursement packets were archived and retained in accordance with grant and federal requirements. Effect: The absence of these records could impede the ability to verify proper grant administration and verify submitted expenditures were allowable costs incurred in accordance with the federal award agreement, which could impact future funding eligibility. It also represents a potential noncompliance with federal grant requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period.

Criteria or Specific Requirement: In accordance with the grant agreements and applicable federal record retention standards (2 CFR 200.334), recipients of federal funds must maintain all records pertinent to the grant—including required progress and financial reports—for a minimum of three years from the date of submission of the final expenditure report. Condition and Context: Solvista Health did not retain certain key documents required to be retained under federal regulation and specific grant agreements. Specifically, Solvista Health was unable to provide quarterly reports, expenditure reimbursement packets submitted to the grantors, project expenditure reports, or other grant-related records necessary to demonstrate compliance with federal reporting and record retention standards under the federal programs. Questioned Costs: N/A Cause: Solvista Health did not implement adequate internal controls to ensure that submitted reports and expenditure reimbursement packets were archived and retained in accordance with grant and federal requirements. Effect: The absence of these records could impede the ability to verify proper grant administration and verify submitted expenditures were allowable costs incurred in accordance with the federal award agreement, which could impact future funding eligibility. It also represents a potential noncompliance with federal grant requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: Solvista Health should strengthen its document retention policies and processes and implement internal controls to ensure that all required grant reports are consistently reviewed, approved, submitted, retained and retrievable for the required retention period.

Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $25,810 • ALN No. 93.788 - $72,347 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Repeat finding (see 2023-003) Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.

Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $25,810 • ALN No. 93.788 - $72,347 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Repeat finding (see 2023-003) Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.

Criteria: In accordance with 2 CFR § 200.334, recipients and subrecipients of federal awards are required to retain all records pertinent to a federal award for a period of three years from the date of submission of the final expenditure or financial report. These records include, but are not limited to, financial records, supporting documentation, statistical records, and all other records pertinent to the federal award. The County is expected to retain copies of all grant agreements to ensure it can identify and comply with all applicable terms, conditions, and regulatory requirements associated with the funding. Condition: CLA observed that the County did not retain copies of the grant agreements for the Home Partnership Investment Program, and the Local Assistance and Tribal Consistency Fund Program. Questioned costs: None noted. Context: CLA was unable to obtain the grant agreements for the Home Partnership Investment Program, and the Local Assistance and Tribal Consistency Fund Program, as the County was unable to provide copies upon request. Cause: The management was unable to retain copies of the grant agreements due to the considerable passage of time since their issuance. Effect: Due to the absence of the original grant agreements, the County may not be fully aware of, or in compliance with, all applicable grant requirements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This process should ensure that key documents are securely stored, easily accessible, and periodically reviewed to support ongoing compliance with grant requirements. Additionally, the County should work with granting agencies to obtain copies of any missing agreements and perform a comprehensive review to identify and address any outstanding compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.

Criteria: In accordance with 2 CFR § 200.334, recipients and subrecipients of federal awards are required to retain all records pertinent to a federal award for a period of three years from the date of submission of the final expenditure or financial report. These records include, but are not limited to, financial records, supporting documentation, statistical records, and all other records pertinent to the federal award. The County is expected to retain copies of all grant agreements to ensure it can identify and comply with all applicable terms, conditions, and regulatory requirements associated with the funding. Condition: CLA observed that the County did not retain copies of the grant agreements for the Home Partnership Investment Program, and the Local Assistance and Tribal Consistency Fund Program. Questioned costs: None noted. Context: CLA was unable to obtain the grant agreements for the Home Partnership Investment Program, and the Local Assistance and Tribal Consistency Fund Program, as the County was unable to provide copies upon request. Cause: The management was unable to retain copies of the grant agreements due to the considerable passage of time since their issuance. Effect: Due to the absence of the original grant agreements, the County may not be fully aware of, or in compliance with, all applicable grant requirements. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management establish and maintain a formal process for the retention and organization of all grant-related documentation. This process should ensure that key documents are securely stored, easily accessible, and periodically reviewed to support ongoing compliance with grant requirements. Additionally, the County should work with granting agencies to obtain copies of any missing agreements and perform a comprehensive review to identify and address any outstanding compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.

2024-001: Department of Health and Human Services - Temporary Assistance for Needy Families (TANF), Federal Assistance Listing #93.558; Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054. Criteria: The Organization should have processes and procedures in place to keep and maintain client eligibility records, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, we noted that the Organization was unable to locate records substantiating the eligibility of clients served. Context: During testing, the Organization was unable to find supporting eligibility records for 31 out of the 60 samples that received services as part of a federal program. The sample was not intended to be, and was not, a statistically valid sample. Cause/Effect: Internal control processes over proper maintenance of clients’ records were not operating effectively, causing documentation to not be located. Questioned Costs: Unknown. Identification of Repeat Finding: Repeat Finding 2023-003. Recommendation: We recommend procedures are implemented to ensure proper maintenance of client records. Views of Responsible Officials: Management agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. All program staff will receive updated training on eligibility requirements, supporting documents to track such requirements, and supports throughout the year to ensure eligibility requirements are met and documented. Documents will also be reviewed regularly to ensure completeness against eligibility requirements. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

2024-002: Department of Health and Human Services - Temporary Assistance for Needy Families (TANF), Federal Assistance Listing # 93.558; Pass Through Virginia Department of Social Services, Pass Through Entity Identifying Number BEN-21-054. Criteria: The Organization should have effective policies and procedures in place to ensure there is proper documentation supporting funds were used in compliance with the federal award, per 2 CFR 200.303 and 2 CFR 200.334. Condition: During our audit, it was noted that there was not an effective process in place to keep and maintain the required records to support pay-for-performance outputs and outcomes. Context: The Organization was unable to provide documentation supporting the allowability of 6 of the 60 samples selected for testing. Cause/Effect: Internal control processes over maintenance of records supporting pay-for-performance outcomes and ouputs were not operating effectively from July 2023 through June 2024. Questioned Costs: $6,800 Identification of Repeat Finding: N/A Recommendation: We recommend that the Organization implements a review process to ensure that documentation is retained to support pay-for-performance outputs and outcomes submitted to the grantor. Views of Responsible Officials: Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support program activities and reports submitted to the grantor. All staff charged with maintaining client documentation will receive updated training on recordkeeping requirements, supporting documents specifying such requirements, and supports throughout the year to ensure documents are properly maintained and verified. Documents will be reviewed regularly for completeness and specifically cross-checked with quarterly report and invoice information directly by program leadership prior to submission. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

Finding 2024-002: Failure to Follow Recordkeeping Requirements for Expenditures (Material Weakness) Federal Agency: United States Department of Agriculture Federal Program Name: COVID-19 - Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments Assistance Listing Number: 10.182 Pass-Through Entity: State of Florida Department of Agriculture Compliance Requirement: Allowable Costs/Cost Principles Criteria: 2 CFR Section 200.334, requires recipients and subrecipients to retain all Federal award records for three years from the date of submission of their final financial reports (quarterly or annually). Records include, but are not limited to, financial records, supporting documentation, and statistical information. Additionally, 2 CFR Section 200.403, requires that costs must meet certain criteria to be allowable under federal awards, specifically 2 CFR Section 200.403(g), requires adequate documentation of those costs. Condition: During our testing, the Organization was unable to provide appropriate supporting documentation that evidenced a proper activity was conducted using federal funding, and further we could not determine if the costs incurred were allowable. Additionally, we noted that the Organization did not establish adequate internal controls to ensure supporting documentation was maintained to evidence that compliance was achieved. Cause: The Organization’s internal controls were not effectively designed over recordkeeping of food purchases. Known Questioned Costs: $166,610 Context: The total sample size was 100 items of expense, which was determined to be a statistically valid sample. 10 out of the 100 items tested were not supported by appropriate documentation. 5 out of 100 items tested included freight costs that were included in the food costs. Freight should have been separated and classified as an administrative cost. These items resulted in the questioned costs calculated above and the noncompliance reported. The total population of expenditures charged to the federal program, from which our sample was selected, was $14,401,876. Effect: Federal funds may have been used for unallowable costs and therefore the purpose of the award may not have been met. Overall, this results in noncompliance with federal award requirements. Recommendation: We recommend the Organization evaluate its internal controls over allowable costs, recordkeeping and recording of federal expenditures and implement internal control procedures to ensure documentation is appropriately maintained for the required timeframe. Ongoing monitoring of the controls designed should be established to ensure future failures are minimized.

Finding 2023-003: Reporting Federal Program: Economic Adjustment Assistance [AL #11.307]. Criteria: Per 2 CFR 200.334, financial records, supports documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: The Bureau was unable to provide documentation that their annual report was submitted to the Kentucky Department of Tourism. As such, the report was unable to be tested. Cause: Controls were not in place to ensure records were maintained in accordance with the Uniform Guidance. Effect: The reporting requirements were unable to be tested. Questioned Costs: None Context: This is not a systemic problem. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Bureau maintain all records related to Federal awards, including making copies of reports submitted, to ensure compliance with the award. Management Response: The management team received limited guidance on the testing, reporting, and retention requirements of federal funds. In the future, copies of all reports and documentation of timely submission will be maintained by the management team.

#2023-010 – Major Federal Award Finding – Document Retention Nature of Finding: Compliance Finding – Uniform Guidance Administrative Requirements and Material Weakness in Internal Controls Over Compliance This is a repeat of prior year finding #2022-011. Criteria/Condition: Federal regulations 2 CFR 200.334 provides that a non-federal entity must retain all records pertinent to a federal award for a minimum period of three years from the date of submission of the annual financial report. We noted during testing that records were not consistently being maintained. Cause/Context: For 4 of the 40 expenditures selected for testing, the Organization was unable to provide appropriate invoice documentation supporting the amount charged to the grant. Effect: Federal expenditures could be charged to the grant at incorrect amounts or for unallowable costs. Recommendation: We recommend the Organization implement a document retention policy that is consistent with the federal document retention requirements. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

#2023-010 – Major Federal Award Finding – Document Retention Nature of Finding: Compliance Finding – Uniform Guidance Administrative Requirements and Material Weakness in Internal Controls Over Compliance This is a repeat of prior year finding #2022-011. Criteria/Condition: Federal regulations 2 CFR 200.334 provides that a non-federal entity must retain all records pertinent to a federal award for a minimum period of three years from the date of submission of the annual financial report. We noted during testing that records were not consistently being maintained. Cause/Context: For 4 of the 40 expenditures selected for testing, the Organization was unable to provide appropriate invoice documentation supporting the amount charged to the grant. Effect: Federal expenditures could be charged to the grant at incorrect amounts or for unallowable costs. Recommendation: We recommend the Organization implement a document retention policy that is consistent with the federal document retention requirements. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

FINDING 2023-006 Subject: COVID-19 - Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii- Reporting Federal Agency: Department of Housing and Urban Development Federal Programs: COVID-19 - Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii Assistance Listings Number: 14.228 Federal Award Number and Year (or Other Identifying Number): CV-CV1-233 Pass-Through Entity: Indiana Office of Community and Rural Affairs Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 25 JEFFERSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the County in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The passthrough agency required the County to submit a CDBG-CV report on Jobs Retained. The County collected the required information via phone calls made by one individual who compiled the information and submitted the required CDBG-CV report on Jobs Retained for the grant program without a documented oversight or review process. Furthermore, supporting documentation for the report was not retained for audit. Due to the lack of supporting documentation, we were unable to determine the accuracy of the report submitted. The lack of internal controls and the failure to maintain adequate supporting documentation was isolated to the CDBG-CV Report on Jobs Retained report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Management had not established a system of internal controls that would have ensured that adequate supporting documentation would have been maintained and made available for audit. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, we could not determine the County's compliance with the CDBG-CV Report on Jobs Retained report. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. INDIANA STATE BOARD OF ACCOUNTS 26 JEFFERSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County strengthen its system of internal controls to provide for a segregation of duties in the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation is retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2023-003: Reporting Federal Program: Economic Adjustment Assistance [AL #11.307]. Criteria: Per 2 CFR 200.334, financial records, supports documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: The Bureau was unable to provide documentation that their annual report was submitted to the Kentucky Department of Tourism. As such, the report was unable to be tested. Cause: Controls were not in place to ensure records were maintained in accordance with the Uniform Guidance. Effect: The reporting requirements were unable to be tested. Questioned Costs: None Context: This is not a systemic problem. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Bureau maintain all records related to Federal awards, including making copies of reports submitted, to ensure compliance with the award. Management Response: The management team received limited guidance on the testing, reporting, and retention requirements of federal funds. In the future, copies of all reports and documentation of timely submission will be maintained by the management team.

#2023-010 – Major Federal Award Finding – Document Retention Nature of Finding: Compliance Finding – Uniform Guidance Administrative Requirements and Material Weakness in Internal Controls Over Compliance This is a repeat of prior year finding #2022-011. Criteria/Condition: Federal regulations 2 CFR 200.334 provides that a non-federal entity must retain all records pertinent to a federal award for a minimum period of three years from the date of submission of the annual financial report. We noted during testing that records were not consistently being maintained. Cause/Context: For 4 of the 40 expenditures selected for testing, the Organization was unable to provide appropriate invoice documentation supporting the amount charged to the grant. Effect: Federal expenditures could be charged to the grant at incorrect amounts or for unallowable costs. Recommendation: We recommend the Organization implement a document retention policy that is consistent with the federal document retention requirements. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

#2023-010 – Major Federal Award Finding – Document Retention Nature of Finding: Compliance Finding – Uniform Guidance Administrative Requirements and Material Weakness in Internal Controls Over Compliance This is a repeat of prior year finding #2022-011. Criteria/Condition: Federal regulations 2 CFR 200.334 provides that a non-federal entity must retain all records pertinent to a federal award for a minimum period of three years from the date of submission of the annual financial report. We noted during testing that records were not consistently being maintained. Cause/Context: For 4 of the 40 expenditures selected for testing, the Organization was unable to provide appropriate invoice documentation supporting the amount charged to the grant. Effect: Federal expenditures could be charged to the grant at incorrect amounts or for unallowable costs. Recommendation: We recommend the Organization implement a document retention policy that is consistent with the federal document retention requirements. Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

FINDING 2023-006 Subject: COVID-19 - Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii- Reporting Federal Agency: Department of Housing and Urban Development Federal Programs: COVID-19 - Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii Assistance Listings Number: 14.228 Federal Award Number and Year (or Other Identifying Number): CV-CV1-233 Pass-Through Entity: Indiana Office of Community and Rural Affairs Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 25 JEFFERSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the County in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The passthrough agency required the County to submit a CDBG-CV report on Jobs Retained. The County collected the required information via phone calls made by one individual who compiled the information and submitted the required CDBG-CV report on Jobs Retained for the grant program without a documented oversight or review process. Furthermore, supporting documentation for the report was not retained for audit. Due to the lack of supporting documentation, we were unable to determine the accuracy of the report submitted. The lack of internal controls and the failure to maintain adequate supporting documentation was isolated to the CDBG-CV Report on Jobs Retained report. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Management had not established a system of internal controls that would have ensured that adequate supporting documentation would have been maintained and made available for audit. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, we could not determine the County's compliance with the CDBG-CV Report on Jobs Retained report. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. INDIANA STATE BOARD OF ACCOUNTS 26 JEFFERSON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County strengthen its system of internal controls to provide for a segregation of duties in the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation is retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2023-005: Significant Deficiency – Documentation Retention Federal grantor: Department of Commerce Condition: The Chamber was unable to provide supporting documentation for one expense sample. Criteria: According to 2 CFR § 200.334, recipients of federal awards must retain financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award for a period of three years from the date of submission of the final expenditure report. Cause: The lack of documentation appears to result from inadequate procedures or oversight in retaining and securely storing required financial records related to the federal program. Effect: Failure to retain supporting documentation compromises the Chamber's ability to demonstrate allowability of costs, may result in questioned costs, and exposes the Chamber to risk in audits or federal monitoring reviews. Recommendation: We recommend the Chamber enhance its record retention policies and internal controls to ensure that all documentation supporting federal program expenditures is retained in compliance with 2 CFR § 200.334. Staff responsible for federal grants should receive training on documentation and retention requirements. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with the findings and will improve its record retention practices to ensure all supporting documentation is properly maintained in compliance with federal requirements.

Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: SLT – 8809: Project Name: HHSC Section 33; HHSC Section 12: Rural Hospitals, HHSC Section 22: Sunrise Canyon Hospital November 8, 2021 – December 31, 2026 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), a non-Federal entity must: Establish 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 be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR 200.334, financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass through entity in the case of a subrecipient. Federal awarding agencies and pass-through entities must not impose any other record retention requirements upon non-Federal entities. In the 2021 Texas Senate Bill 8, HHSC was appropriated money in various sections of the bill received by Texas from the Coronavirus State Fiscal Recovery Fund for the following purposes related to costs incurred during the period beginning October 8, 2021, and ending November 8, 2023, due to the coronavirus pandemic:  Section 11(a) – funding for the construction of a state hospital in Dallas, Texas.  Section 12 – funding for grants to support rural hospitals that have been affected by the COVID-19 pandemic.  Section 13 – funding for the creation of a consolidated internet portal for Medicaid and the Children’s Health Insurance Program medical services provider data.  Section 14 – funding for technology updates to the Medicaid eligibility computer system.  Section 15 – funding for COVID-19 related expenses incurred by the Texas Civil Commitment Office related to consumable supplies and travel.  Section 22 – funding for the expansion of capacity of Sunrise Canyon Hospital.  Section 33 – funding to administer one-time grants related to providing critical staffing needs resulting from frontline healthcare workers affected by COVID-19, including recruitment and retention bonuses for staff. Condition: Audit procedures included a selection of 60 sampled expenditures totaling $143,092,786 incurred during the fiscal year to test allowability with the grant awards. We noted that for 48 out of the 60 samples totaling $9,600,062, the agency did not obtain supporting documentation from the vendor to verify that the amounts advanced to the vendor were expended on allowable costs. We were unable to substantiate the amounts expended by the vendor and allowability of those expenditures in accordance with the relevant Senate Bill 8 section and the Department of the Treasury Final Rule. Questioned costs: $9,600,062. Context: See “Condition.” Cause: HHSC is not fully monitoring the use of program funds through collection, review, and maintenance of invoices supporting the expenditures. Effect: Failure to maintain adequate documentation pertinent to a federal award may result in noncompliance with grant terms and conditions. Repeat finding: No Recommendation: HHSC should implement policies and procedures to ensure documentation is maintained for a period of at least three years from the date of submission of the final expenditure report for the grant in accordance with 2 CFR 200.334. Views of responsible officials: HHSC concurs with the finding.