Findings Citing § 200.502

Finding 2024-001 – ReportingInformation of the federal program:Federal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.391, COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare CrisisPass-Through Grantor: Chicago Department of Public HealthFederal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious DiseasesPass-Through Grantor: Chicago Department of Public HealthCriteria or specific requirement (including statutory, regulatory, or other citation):Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”Condition:Certain expenditures related to the COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis and the COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases were overstated by $347,352 and $164,120, respectively, on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.Cause:Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.Effect or Potential Effect:Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.Questioned costs:None.Context:Endeavor reported expenditures of $872,758 on the preliminary SEFA, but on the final SEFA reported $525,406 related to the COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis. Endeavor reported expenditures of $1,233,464 on the preliminary SEFA, but on the final SEFA reported $1,069,344 related to the COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases.Identification as a repeat finding, if applicable:This is a repeat finding of 2023-001.Recommendation:Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.Views of responsible officials:Management acknowledges the findings related to SEFA reporting. The issue arose from miscommunication in determining which expenditures should be reported for the programs in question. We recognize the importance of accurate and complete reporting. We will enhance our review and communication processes to ensure clarity between program managers and the finance team when identifying reportable expenditures. We have already taken steps to address this issue by:• Creating a new policy and procedure for SEFA reporting and establishing clear guidance and documentation for expenses that should be included in the SEFA.• Implementing an expanded review process to ensure accuracy prior to submission.

Finding Number: 2024-007 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Grantor: U.S. Department of Health and Human Services Passed-through: County of Sacramento Award No. and Year: DHA-PRTS-NM-07-25-A1; FY 2024 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Organization) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502. In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA and expenditures reported for the Temporary Assistance for Needy Families program we noted the Organization overstated expenditures totaling $138,217. The December 31, 2024 SEFA was corrected for this reporting error. Cause: The Organization did not have adequate internal controls to ensure the Schedule was prepared completely and accurately. Effect: Prior to the correction, expenditures for the Temporary Assistance for Needy Families program were overstated by $138,217. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. Repeat Finding from Prior Years: No. Recommendation: We the recommend the Organization enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2024-007 Reporting Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP3474, 2021 Pass-Through Agency: N/A – Federal Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.510(b) states that the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502, basis for determining federal awards expended. In addition, the U.S. Department of the Treasury requires recipients of funds to submit Project and Expenditure reports that include, by project, current period obligations, cumulative obligations, current period expenditures, and cumulative expenditures. The frequency of reporting is dependent on the size of the entity and amount of funding received. Condition: During 2024, McLeod County identified an additional $1,302,426 in COVID-19 – Coronavirus State and Local Fiscal Recovery Funds expenditures that were not included in the County’s original SEFA nor in the original population of expenditures provided for audit. In addition, expenditures documented in the County’s annual Project and Expenditure report through March 31, 2025, were understated by $1,515,400, and expenditures documented in the County’s annual Project and Expenditure report through March 31, 2024, were understated by $374,095. Questioned Costs: None. Context: The U.S. Department of the Treasury relies on accurate reporting of program costs to ensure grant funds are spent in accordance with program requirements. McLeod County is required to submit annual Project and Expenditure reports; the County submitted annual reports in both April 2024 and April 2025. Effect: Federal expenditures provided to the auditors were not fairly reported in the SEFA. In addition, the County did not accurately report expenditures on its Project and Expenditure reports as of March 31, 2025, and March 31, 2024. Cause: Due to human error, the County reported funds as obligated instead of expended because of additional projects that are ongoing. Recommendation: We recommend the County implement controls that ensure proper identification of federal expenditures in accordance with program requirements and that federal program reports are accurate. We also recommend the County submit revised Project and Expenditure reports as of March 31, 2025, and March 31, 2024. View of Responsible Official: Concur

Section III – Findings and questioned costs for Federal awards U.S. Department of Homeland Security, Federal Emergency Management Agency Passed through Missouri Department of Public Safety, State Emergency Management Agency Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing #: 97.036 Finding: 2024 – 001 SIGNIFICANT DEFICIENCY Reporting Condition: During our original audit, the Cooperative initially failed to identify and properly report $878,271 of FEMA aid funding received from the State of Missouri. This error was identified subsequent to the issuance of the report and requires a re-issuance of the related audit reports. The internal control system did not prevent or detect this error to trigger the SEFA preparation process. Cause: The Cooperative's procedures for identifying and reporting federal expenditures were insufficient. The Cooperative finance personnel initially misunderstood the proper period for reporting FEMA disaster assistance expenditures. While the FEMA aid funding was approved by the State on December 20, 2024, with inspection by SEMA completed January 15, 2025, management initially concluded the expenditures should be reported in 2025 based on the cash receipt date. However, the expenditures should have been reported in 2024 when the eligible disaster recovery costs were actually incurred. This timing confusion, combined with the Cooperative's infrequent receipt of federal funding, resulted in the omission from the original 2024 SEFA. Effect: The initial error resulted in the audit report being issued without the required single audit report. While this error has been corrected, the control deficiency increases the risk that future federal awards could be incorrectly reported on the SEFA, potentially resulting in noncompliance with federal reporting requirements and incomplete or inaccurate identification of major programs subject to audit. Questioned Costs: $0 Criteria: 2 CFR 200.510(b) requires that the auditee prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires that non-federal entities establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the related awards. Recommendation: We recommend the Cooperative implement written procedures for SEFA preparation that include: (1) obtaining and reviewing all award agreements to identify federal funding sources; (2) maintaining a master listing of all awards that identifies the funding source (federal/state/local) and applicable Assistance Listing Numbers; (3) implementing cutoff procedures to ensure federal expenditures are reported in the correct period based on when eligible costs are incurred, not when funds are received from federal systems; and (4) requiring independent review of the SEFA by someone knowledgeable about federal compliance requirements who verifies completeness against award documentation and proper period reporting. We note that the Cooperative's finance office maintains good communication practices with auditors regarding federal funding when they are aware of such awards; therefore, strengthening the internal identification and cutoff processes will enhance the Cooperative's ability to provide complete, accurate, and timely information to auditors about all federal funding sources. Views of responsible personnel and planned corrective actions: Management concurs with this finding. The Cooperative will implement the following corrective actions prior to December 31, 2025: • The CFO will document written procedures for SEFA preparation that specifically address proper period cutoff based on when costs are incurred versus when funds are received. • All current grant agreements will be reviewed to identify federal funding sources and ensure compliance with the single audit threshold. • The CFO will perform quarterly and annual reviews of federal expenditure reporting for completeness, accuracy, and proper period reporting. • Prior to year-end, the CFO will independently review all award documentation to the draft SEFA against all grant documentation to verify completeness and proper period reporting.

Finding 2024-002: Information on the Federal Program: Compliance Requirements: Other—Schedule of Expenditure of Federal Awards Preparation Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance. Criteria: 2 CFR 200.510 indicates that the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with 200.502 Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as: expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: The Organization failed to prepare a complete and accurate SEFA for the year ended December 31, 2024. The SEFA is a required supplementary schedule that provides detailed information on all federal awards received and expended during the fiscal year, in accordance with 2 CFR 200.510. Cause: The noncompliance resulted from a deficiency in the Organization’s internal controls. The Organization does not have established policies and procedures to ensure all federal awards are properly identified, tracked, and included in the SEFA preparation process. Effect or Potential Effect: Due to the control deficiencies described above, if not for auditor assistance, inaccurate expenditures result in a high risk that material noncompliance with federal regulations could occur and not be detected and corrected in a timely manner; inaccurate reporting to federal agencies on the Organization’s federal expenditures; and persistent noncompliance can lead to potential loss of funding. Questioned costs: No questioned costs were identified as a result of this compliance finding. Context: The Organization mistakenly omitted to report expenditures of federal award expenditures on an accrual basis under the Sexual Risk Avoidance, ALN 93.060, and Title V Sexual Risk Avoidance Education Program (Discretionary Grants), ALN 93.787. Recommendation: We recommend that the Organization establish formal procedures to ensure SEFA preparation along with all federally funded contracts included in the SEFA as expenditures; implement a robust process to track all federal awards under government auditing standards, provide training on Uniform Grant Guidance, including SEFA preparation; perform management review to ensure the SEFA is accurate, complete, and prepared in a timely manner. Views of responsible officials and planned corrective actions: Management acknowledges the omission of the auditee’s prepared SEFA. Management is committed to properly preparing the SEFA, and to address this oversight, management will identify trainings for accounting personnel related to SEFA reporting and for those reviewing the schedule, to ensure its accuracy.

Assistance Listing, Federal Agency, and Program Name ALN 14.218, U.S. Department of Housing and Urban Development, Entitlement Grants Cluster (CDBG), Community Development Block Grants/Entitlement Grants and ALN 20.507, U.S. Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Federal Award Identification Number and Year All grants under ALN Pass through Entity N/A Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR Section 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended determined in accordance with Section 200.502. Condition The CDBG Cluster and Federal Transit Cluster expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Questioned Costs None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported Not applicable Identification of How Questioned Costs Were Computed Not applicable Context The CDBG Cluster expenditures were overstated by $792,426 and the Federal Transit Cluster expenditures were overstated by $365,634. The final SEFA has been corrected. Cause and Effect Controls in place did not ensure the SEFA was complete and accurate and as a result, the SEFA needed to be adjusted for two federal clusters. This did not impact major program determination. Recommendation The City should implement a process to ensure the expenditures reported on the SEFA are complete and accurate. Views of Responsible Officials and Corrective Action Plan Due to turnover and the loss of a long term employee new processes were implemented to prepare reporting and documentation processes for the Federal Transit Cluster. Written Standard Operating Procedures have been generated and will be updated as necessary. Reporting and draw processes have been updated to include written signatures of approval for the documentation. The staff in transit and finance work closely together to ensure the completeness of records. City of Greeley will also be organizing a formalized grants team that will be dedicated to all grant activities including the SEFA and correcting the prior staffing insufficiencies.

Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) ALN: 10.904, Milk River Project ALN: 10.923, Stream Restoration and Bridge Replacement for St. Mary Siphon Failure ALN: 15.U01, Replacement of St. Mary and Hallls Coulee Siphons on St. Mary Canal CRITERIA: The Code of Federal Regulations (CFR) Section §200.510(b) states in part: "The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended." The schedule must provide total Federal awards expended for each individual Federal program. CFR 200.302(b)(1) requires that the nonfederal entity must identify in its accounts and on the schedule of expenditures of federal awards all federal awards received and expended, as well as the federal programs under which they were received. Federal program and award identification must include, as applicable, the Assistance Listing program title and number, the federal award identification number and year, the name of the federal agency, and the name of the pass-through entity, if any. CONDITION: The ALN 10.923, Stream Restoration and Bridge Replacement for St. Mary Siphon Failure, was left off the prepared SEFA. Amounts reported for ALN 10.904 and ALN 15.U01 did not agree to the accounting records. CONTEXT: The SEFA was misstated as follows: • Understated for ALN 10.904 by $196,980; • Understated for ALN 10.923 by $105,977; and • Overstated for ALN 15.U01 by $1,978,224. The net effect was an overstatement of $1,675,267 for total federal expenditures. EFFECT: The SEFA provided was not complete and accurate. QUESTIONED COSTS: None CAUSE: The internal controls for the preparation of the SEFA and review of the SEFA were not present to ensure the SEFA was complete and accurate. RECOMMENDATION: We recommend the MRJBOC prepare written procedures on how to put together the SEFA and strengthen internal controls to ensure all federal awards are included on the SEFA. We also recommend that the SEFA be reviewed by someone other than the preparer for completeness and accuracy prior to providing to the auditor. MRJBOC RESPONSE: MRJBOC acknowledges the deficiencies identified in the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA). During 2024, the organization experienced a significant increase in federal funding activity related to emergency response and infrastructure replacement projects. The rapid expansion of federal programs, addition of funds and reporting requirements exceeded existing internal documentation and review processes. To strengthen compliance controls and ensure SEFA accuracy in future reporting periods, MRJBOC will implement the following corrective actions: • Develop and formalize written SEFA preparation procedures, including grant identification, ALN verification, and reconciliation to general ledger balances. • Establish a dual-review process in which the SEFA is reviewed and approved by a party independent from the preparer prior to submission to auditors. • Maintain a centralized federal grant tracking log that includes award numbers, funding sources, drawdowns, and cumulative expenditures. These measures will improve internal control over federal reporting, enhance accuracy, and ensure compliance with federal audit requirements.

Criteria: 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, and §200.302 (b), Financial Management. The recipients financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal program under which they were received. Federal program and federal award identification must include, as applicable, the federal assistance listing title and number, federal award identification number, name of the federal agency, and name of the pass-through entity, if any. Additional Criteria: 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F – Audit Requirements, §200.510, Financial Statements. Schedule of Expenditures of Federal Awards – The auditee also must prepare a schedule of expenditures of federal awards for the period covered by the auditee’s financial statements, which must include the total federal awards expended, as determined in accordance with §200.502, Basis for Determining Federal Awards Expended. At a minimum, the schedule must provide total federal awards expended for each individual federal program and the federal assistance listing number or other identifying number when the federal assistance listing information is not available. For a cluster of programs, also provide the total for the cluster. Condition: PCRI did not maintain a complete schedule of expenditures of federal awards. Cause: PCRI did not adequately track which government grants were federally-funded, resulting in an incomplete schedule of expenditures of federal awards. Effect: Failure to prepare an accurate and complete schedule of expenditures of federal awards results in noncompliance with 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, §200.302, Financial Management, and Subpart F – Audit Requirements, §200.510, Financial Statements. Recommendation: We recommend that PCRI document and implement policies and procedures to ensure the schedule of expenditures of federal awards is accurate and complete in accordance with 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, §200.302, Financial Management, and Subpart F – Audit Requirements, §200.510, Financial Statements, in order to obtain accurate calculations of major federal programs for the Single Audit and to ensure that PCRI is in compliance with all of the reporting requirements as to identify the source and application of funds for federally-funded activities.

Understated SEFA (Material Weakness) Program Information: All programs Criteria: L. Reporting- The auditee must prepare a schedule of expenditures of Federal awards (the “SEFA”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502 Basis for determining Federal awards expended. Condition: During our audit of the financial statements for the fiscal year ending December 31, 2024, we identified that the Schedule of Expenditures of Federal Awards (SEFA) was not prepared in accordance with the requirements set forth by the Uniform Guidance (2 CFR Part 200) and was incomplete. Cause: Insufficient internal control and administrative oversight. Effect or Potential Effect: As a result of the incorrect preparation, the SEFA did not accurately reflect the federal awards expended during the fiscal year. This could potentially lead to noncompliance with Federal requirements and affect the accuracy of the financial statements. Recommendation: We recommend that the entity implement the following corrective actions:  Provide training to the staff responsible for preparing the SEFA to ensure they understand the requirements of the Uniform Guidance.  Establish a review process to verify the accuracy and completeness of the SEFA before submission.  Utilize a checklist or other tools to ensure all required information is included in the SEFA. Views of Responsible Officials: Management agrees with the finding and the auditors’ recommendation. See Corrective Action Plan at the end of the report.

2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the City’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL number information is not available. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The City’s internal control procedures identified and properly recorded $141,051 of Coronavirus relief funds and $577,081 of Highway Planning and Construction pass-through expenses for PID #113961 for recording in their Schedule of Federal Awards Expenditures (Schedule). The City did not identify $381,346 of pass-through expenses for PID #115721 in the Schedule related to the Highway Planning and Construction Funds. Adjustments, to which management have agreed, are reflected in the accompanying Schedule. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit.

Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 5. Public Health Institute (PHI) Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Activities Allowed or Unallowed Criteria: Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements. 2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger). In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended. Condition: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025

Information on Federal Programs: 93.083 – Centers for Disease Control and Prevention: Prevention of Disease, Disability, and Death through Immunization & Control of Respiratory & Related Diseases. Criteria or Specific Requirements: 2 CFR §200.510(b) requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee’s financial statements that includes Federal awards expended during that fiscal year. 2 CFR §500.502 provides that the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Condition: During testing of the SEFA for the year ended December 31, 2024, we noted that certain Federal program expenditures related to activities incurred in fiscal year 2023 were reported in the 2024 SEFA instead of in the 2023 SEFA. Cause: Management’s procedures for preparing and reviewing the SEFA did not include sufficient controls to ensure that expenditures are reported in the correct fiscal year. Effect: The SEFA for the year ended December 31, 2023 was incomplete, and the SEFA for the year ended December 31, 2024 includes expenditures that related to activities incurred in fiscal year 2023. Although the expenditures were allowable costs of the Federal program, the timing misstatement affects the accuracy of SEFA presentation and could affect the usefulness of SEFA information to Federal agencies and pass-through entities in their monitoring and oversight. The error did not impact the major program selection process for 2023 or 2024.Perspective: This issue was identified during our testing of the SEFA for the year ended December 31, 2024, when we noted that ATS reported $114,984 of Federal award expenditures in 2024 that related to activities incurred in fiscal year 2023. These expenditures should have been reported in the SEFA for year ended December 31, 2023. Questioned Costs: None. Identification as a Repeat Finding: Not applicable. Recommendation: ATS should implement formal procedures for compiling the SEFA, including (1) reconciling SEFA amounts to the general ledger and other supporting records, (2) performing a year-end review to confirm that expenditures are reported in the correct fiscal year in accordance with 2 CFR §200.502 and 2 CFR §200.510(b), and (3) documenting supervisory review of the SEFA prior to finalization.

Reporting – Incomplete Schedule of Expenditures of Federal Awards Identification as a Repeat Finding: Not a repeat finding Federal Awards: 21.027 - Coronavirus State and Local Fiscal REcovery Funds Finding: The Authority did not properly identify proceeds received under a pass-through loan program as including federal award funds under the U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds program, and therefore the loan was improperly excluded from the schedule of expenditures of federal awards (SEFA). Sample Size and Population: Sampling was not applicable to this finding. Questioned Costs: None Criteria: The Authority is required to report all federal awards expended during the audit period on the SEFA. For federal loan programs, federal awards expended include the value of new loans received during the audit period, and the SEFA notes must identify outstanding loan balances at the end of the audit period. 2 CFR § 200.502(a)(3), 2 CFR § 200.502(b)(1), and 2 CFR § 200.510(b)(5). Condition: The Authority’s originally issued 2024 SEFA omitted $2,477,915 of federal expenditures related to a pass-through loan from the Washington State Department of Commerce. The loan included federal funds from the U.S. Department of the Treasury’s Coronavirus State and Local Fiscal Recovery Funds program, Assistance Listing 21.027. The entire federal portion of the loan was drawn during the year ended December 31, 2024, and the outstanding balance of the federal portion of the loan was $2,477,915 at December 31, 2024 and $0 at December 31, 2023. The omission was identified after the original 2024 Single Audit report had been issued Cause: The Authority did not have an effective process to ensure that all departments communicated federal award and loan information to the finance department for SEFA reporting. Effect: The originally issued SEFA was materially understated by $2,477,915, and the SEFA notes omitted the $2,477,915 outstanding federal loan balance at December 31, 2024. The omission affected the major program determination because Assistance Listing 21.027 was not included in the original SEFA or original major program selection. As a result, the originally issued Single Audit reporting package did not include the revised SEFA amounts, did not identify ALN 21.027 as a major program, and did not include auditor testing and reporting over the ALN 21.027 major program. Recommendations: Management should implement procedures to ensure all grant agreements, loan agreements, pass-through award notices, and related amendments are reviewed by the finance department to determine whether they include federal funds. Management should also require communication between project management and finance personnel, perform a year-end reconciliation of loan draws and outstanding balances to the SEFA, and document review of the SEFA and related notes before issuance. Management Response: Management response is reported in the “Corrective Action Plan” at the end of this report. Contact Person: Lowel Krueger, Executive Director

Federal Award Number and Award Year 4486DR-FL and January 1, 2024 to December 31, 2024 Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards for the period covered by the entity’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA. Condition and Context The Organization did not have adequate controls in place related to the identification and reporting of federal expenditures for the COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) program (FEMA) on the SEFA. Specifically, the Organization lacked controls to ensure expenditures incurred for FEMA were recognized on the SEFA when obligated. As a result, $4,644,457 of FEMA expenditures were omitted from the December 31, 2024 SEFA. Possible Cause and Effect Management did not perform appropriate risk assessment procedures related to federal awards that have unique recognition criteria such as FEMA. Specifically, there was not a control in place to ensure FEMA expenditures were recognized on the SEFA based on when the FEMA award was both obligated and expenditures were incurred. Failure to establish effective internal controls over the preparation of the SEFA may prevent the Organization from reporting accurate information and completing an audit in accordance with the Uniform Guidance. Questioned Cost Not applicable Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat of Prior Finding Not a repeat finding. Recommendation We recommend that the Organization strengthen its processes and internal controls over ensuring that expenditures have been reported completely and accurately on the SEFA. View of Responsible Official Management agrees with the noted finding.

Federal Award Findings and Questioned Costs: Finding Number: 2024-002 Federal Assistance Listing Number: 97.036 Program: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Agency Name: Federal Emergency Management Agency Federal Award Number: D20-528 AND D20-287 Federal Award Year: 2024 Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards (Schedule) for the period covered by the entity’s financial statements, which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately and completely reported on the Schedule. Conditions Found The District did not have adequate internal controls related to the reporting of expenditures on the Schedule for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (FEMA). Specifically, the District’s review controls over the accuracy and completeness of the Schedule were not designed to operate at an appropriate level of precision. As a result, $4,485,028 of FEMA expenditures had been omitted from the December 31, 2024 Schedule. Cause In discussing the conditions with District management, they stated the error was caused by the management review controls in place not operating at a sufficient level of precision to detect the error. Effect Failure to establish effective internal controls over the preparation of the Schedule may prevent the District from completing an audit in accordance with Uniform Guidance. Questioned Costs Not applicable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This finding is not a repeat finding in the immediate prior audit. Recommendation We recommend that the District implement a system of internal controls that is designed and operating at a level of precision to ensure the Schedule is complete and accurate. Views of Responsible Officials The District agrees with the finding and accepts the recommendation.

Reporting – SEFA Preparation Information of the federal program: Federal Grantor: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing No.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) Federal Award Numbers: H76HA31655, H76HA25775, H76HA00617, and P06HA9851 Federal Award Period: April 1, 2022 through March 31, 2025; May 1, 2022 through April 30, 2025; May 1, 2022 through April 30, 2025; and September 1, 2023 through August 31, 2024 Criteria or specific requirement (including statutory, regulatory or other citation): The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (the SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: Ryan White, Part C requires the use of program income under the additive method, which requires program income earned from a federally funded program is added to the federal award amount and used to further program objectives. Under the method, allowable expenditures of program income are included on the SEFA. UPMC’s SEFA did not include expenditures related to program income, which were allowable. Cause: UPMC’s SEFA included grant funds expended under the Ryan White, Part C program but did not include program income funds expended under the Ryan White, Part C program for the year ended December 31, 2024. Effect or potential effect: The expenditures in the SEFA for the Ryan White, Part C a program for the year ended December 31, 2024, were understated which resulted in the improper identification of major federal programs and, therefore, required the restatement of the previously issued Uniform Guidance report to include Ryan White, Part C as a major federal program. Questioned costs: None. Context: Expenditures for Ryan White, Part C were understated by $5,539,365 (as compared to total restated expenditures for Ryan White, Part C of $7,048,401), which resulted in Ryan White, Part C being identified as major federal program upon inclusion of the allowable expenditures from program income. Identification as a repeat finding, if applicable: Yes, this is a repeat of finding 2023-002 from the prior year. Recommendation: UPMC should evaluate its internal controls over the SEFA process to ensure that reported federal expenditures include both grant expenditures and applicable program income expenditures, when required, to support the accurate reporting of federal expenditures. Views of responsible officials: Management concurs with this finding.

Finding 2024-003 Inaccurate SEFA - Reporting - Material Weakness Name of Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Recommendation: We recommend the Organization strengthen its policies, procedures, and controls for the identification of federal awards to ensure a complete and accurate SEFA is prepared in a timely manner. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address SEFA preparation. Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Identification number unavailable. Name of Pass-through Entity (if applicable): City of New Bedford Criteria: In accordance with 2 CFR 200.302 (Financial Management), a grant recipient's financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.510 (Financial Statements), states in part that the auditee must prepare a schedule of expenditures of Federal awards ("SEFA") for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2CFR 200.502. At a minimum, the schedule must include:  All individual federal programs by federal agency.  For federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included.  Provide total federal awards expended for each individual federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available.  Include the total amount provided to subrecipients from each federal program. Condition / Context: The Organization management's review and approval process did not detect the errors that were identified during the audit procedures performed. The errors detected consisted of the understatement of Federal Assistance Listing Numbers 21.027 and 14.251 in the amount of $450,038 and $225,895, respectively, for a total understatement of $675,933. Cause: The Organization's internal controls over the preparation and review of the SEFA were not operating effectively. Material audit adjustments were proposed during the course of the audit that lead to material changes to the SEFA. Effect or Potential Effect: Inadequate controls over the preparation of the SEFA could result in financial misstatements or potential noncompliance. Questioned Costs: None Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization strengthen its policies, procedures, and controls for the identification of federal awards to ensure a complete and accurate SEFA is prepared in a timely manner. Views of Responsible Officials: Management agrees with the finding and is in the process of revising internal controls to address SEFA preparation.

2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.

2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.

Assistance Listing, Federal Agency, and Program Name - 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 21.027, U.S. Department of the Treasury, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - ALN 21.027 SLFRP0127 Pass through Entity - ALN 21.027 - State of Michigan Finding Type - Material weakness Repeat Finding - Yes 2023-002 Criteria - The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program-specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule. Condition - The schedule of expenditures of federal awards (SEFA) was not accurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year ended September 30, 2024, the City expended approximately $2,831,000 of federal funding. The initial draft of the SEFA included the following inaccuracies: ALN 66.818 - The expenditures reported on the SEFA were understated by $148,474. ALN 21.027 - The expenditures reported on the SEFA were overstated by $2,078,221. The SEFA was also ovestated by $116,625 related to a non federal program. The errors noted above have been corrected on the SEFA as of September 30, 2024. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the overstatement of federal expenditures. Recommendation - We recommend the City implement a process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The City will review its process for identifying and communicating federal grant expenditures to its auditors.

Assistance Listing, Federal Agency, and Program Name - 66.818, U.S. Environmental Protection Agency, Brownfields Assessment and Cleanup Cooperative Agreements; 21.027, U.S. Department of the Treasury, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - ALN 21.027 SLFRP0127 Pass through Entity - ALN 21.027 - State of Michigan Finding Type - Material weakness Repeat Finding - Yes 2023-002 Criteria - The Single Audit Act and Uniform Guidance require a nonfederal entity that expends $750,000 or more of federal awards in a fiscal year to have a single or program-specific audit. 2 CFR §200.508 (b) indicates that the auditee must prepare financial statements, including the schedule of expenditures of federal awards in accordance with 2 CFR §200.510. Additionally, 2 CFR §200.502 describes the basis for determining the timing of when federal awards are deemed expended and, therefore, reportable on the schedule. Condition - The schedule of expenditures of federal awards (SEFA) was not accurate. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During the fiscal year ended September 30, 2024, the City expended approximately $2,831,000 of federal funding. The initial draft of the SEFA included the following inaccuracies: ALN 66.818 - The expenditures reported on the SEFA were understated by $148,474. ALN 21.027 - The expenditures reported on the SEFA were overstated by $2,078,221. The SEFA was also ovestated by $116,625 related to a non federal program. The errors noted above have been corrected on the SEFA as of September 30, 2024. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate for the fiscal period under audit. The errors resulted in the overstatement of federal expenditures. Recommendation - We recommend the City implement a process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - The City will review its process for identifying and communicating federal grant expenditures to its auditors.

--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.

--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.

--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.

--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.

--Type of Finding: Material weakness in internal control over compliance --Criteria: The Uniform Guidance (2 CFR Part 200, subpart F) states it is the responsibility of the Organization’s management to ensure internal controls are properly designed and implemented in order to identify federal awards and expenditures of federal awards and to prepare a schedule of expenditures of federal awards (SEFA) that includes the total federal awards expended, as determined in accordance with § 200.502. --Condition and Context: While performing audit procedures, we identified two federal subawards that were not previously identified as such by management and had not been included on the SEFA for the year ended September 30, 2024 as originally presented for audit. The SEFA was subsequently corrected prior to issuance of the audit. The original SEFA was materially misstated due to the exclusion of expenditures under the federal subawards totaling $379,232. --Cause of Condition: Management failed to identify the agreements as federal subawards and the related expenditures for inclusion on the SEFA. --Effect of Condition: Failure to accurately identify all federal awards could cause the SEFA to be materially misstated and the performance of an insufficient major federal award programs audit. --Questioned Costs: None. --Repeat Finding: No. --Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. --Views of Responsible Officials: See attached Corrective Action Plan.

Findings and Questioned Costs Relating to Federal Awards 2024 001 SEFA Control Deficiency U.S. Department of Treasury Community Development Financial Institutions Program (ALN 21.033) Statistically Valid Sample: No, and it was not intended to be. Prior Year Finding: Not a repeat finding. Finding Type: Significant deficiency Criteria CFR 200.502(a) requires expenditures be recorded in the period they occur. Additionally, 2 CFR 200.303(a) states that non federal entities must establish and maintain effective internal control over federal awards that provide 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. Condition and Context During our test work over the Schedule of Expenditures of Federal Awards (SEFA), we noted the Organization incorrectly reported expenditures, in the amount of $693,023, incurred in the fiscal year ended September 30, 2023 on the 2024 SEFA. CFR 200.502(a) requires expenditures be recorded on the SEFA in the period they occur. The 2023 expenditures were incurred during the performance period of the grant and were for activities allowed under the grant, therefore there were no questioned costs or noncompliance related to the expenditures. The Organization’s internal controls were not designed to detect that the expenditures were not timely reported on the SEFA. Cause The significant deficiency arose primarily from a misunderstanding and misapplication of SEFA preparation rules in accordance with CFR 200.502(a), specifically regarding the timing of recording expenditures. Effect Failure to properly report expenditures on the SEFA can lead to a missed or incorrect major program determination. Questioned Costs None. Recommendation We recommend that the Organization strengthen its internal controls to ensure all expenditures are reported on the SEFA in the period incurred to comply with the requirements of CFR 200.502(a). Views of Responsible Officials As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied.

2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.

2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.

2024-003 ─ Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) U.S. Department of Transportation – Federal Transit Cluster (ALN No. 20.507) Federal award year 2023 Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. 2 CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-federal entity to comply with federal statutes, regulations and the terms and conditions of federal awards, such as expenditure/expense transactions associated with grant awards. Condition: We noted that the Schedule of Expenditures of Federal Awards and State Financial Assistance (Schedule) provided to the auditors for the fiscal year ended September 30, 2024 included $56,503,870 of federal expenditures for the Federal Transit Cluster, assistance listing number 20.507, that should have been included in the Schedule for the fiscal year ended September 30, 2023. The County executed an ARPA transportation grant in September 2023 for which prior year eligible incurred costs were applied, however, these expenditures were not reported on the County’s Schedule until FY 2024. The Schedule for fiscal year ended September 30, 2023 was reissued to include the $56,503,870 and the expenditures were removed from the Schedule for the fiscal year ended September 30, 2024. Context: The finding is considered isolated in nature to the federal program in question. Effect: Improper reporting of federal expenditures resulted in a material error on the Schedule. Identification as a repeat finding, if applicable: Yes (2023-006) Cause: The department directly administering this grant did not realize they had to immediately recognize the expenditures associated with the grant at the time of grant award when the decision was made to apply prior eligible incurred costs. The transaction was not recorded until the reimbursement request was submitted in fiscal year 2024. Recommendation: Grant activities including general ledger activity should be reconciled by the departments managing the programs and the information communicated timely to the Office of Financial Management and Budget (OFMB). Depending on the nature and size of the grant programs these reconciliations could occur, monthly, quarterly or yearly, depending on what is most efficient in each individual situation. Also additional training could be provided to help enhance the understanding of grant personnel around some of the important nuances of revenue and expenditure recognition criteria the County must comply with in accordance with generally accepted accounting principles so they provide OFMB with sufficient information to prepare the end of year Schedule or so they can ask questions of OFMB and County Finance and seek assistance for any matters they are unsure of how to process.