Findings Citing § 200.510

Single Audit Process Criteria – Under 2 CFR §§200.508 and 200.510, the City is responsible for preparing a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). Under 2 CFR §200.501, a nonfederal entity that expends $1,000,000 or more in federal awards during its fiscal year must obtain a single audit or program-specific audit. Condition – The City did not maintain a complete listing of federal awards expended during the year ended June 30, 2026. As a result, the initial information provided for the audit did not accurately identify total federal expenditures. Cause – The City had not established a formal process to identify and track expenditures by federal award throughout the year or to reconcile those expenditures to its accounting records when preparing the SEFA. Effect – Without a complete and accurate record of federal expenditures, the City may not identify its single audit requirement on a timely basis, and federal programs may be omitted or misstated on the SEFA. No questioned costs were identified as a result of this finding. Recommendation – The City should establish procedures to identify each federal award, record its Assistance Listing number and award information, and track related expenditures throughout the year. At year-end, the City should reconcile those records to its accounting records, prepare the SEFA, and determine whether the single audit threshold has been met before audit planning begins. Response and Corrective Action Planned – The City will work on a formal process for tracking all federal grants. Conclusion – Response accepted.

Criteria: Per 2 CFR 200.510(b), the auditee must include in the SEFA “the total Federal awards expended for each individual Federal program and the Assistance Listing number”. Statement of Condition: During our audit, we noted that expenditures reported for Assistance Listing 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants were understated by approximately $155,000 on the FY 2025 SEFA. This understatement resulted in the SEFA not accurately reflecting the total federal expenditures for this program as required. Cause: The understatement appears to be due to errors in compiling and reconciling federal expenditures during SEFA preparation. Effect or Potential Effect: An understated SEFA can result in: Federal expenditures being misclassified or omitted; Incorrect major program determination; Potential noncompliance with Uniform Guidance reporting requirements; and inaccurate reporting to the Federal Audit Clearinghouse. Questioned Costs: $- Recommendation: We recommend that management: Strengthen its SEFA preparation procedures to ensure all federal expenditures are captured, reconciled, and accurately assigned to the correct Assistance Listing; implement an internal review process verifying completeness of expenditures, including comparison of SEFA totals to the general ledger and grant-level schedules; and review all federal program totals prior to finalizing the SEFA to ensure compliance with 2 CFR 200.510(b). Management Response: See corrective action plan.

Schedule of Expenditures of Federal Awards Reporting Significant Deficiency - Community Development Block Grant Cluster Entitlement/Special Purpose Grants Federal Granting Agency: U.S. Department of Housing and Urban Development Federal Pass-through Entity: New York City Department of Youth and Community Development Assistance Listing Number: 14.218 Award Number: 99345B Award Year: July 1, 2024 – June 30, 2025 Criteria: OMB Uniform Guidance 2 CFR 200.510(b)(3) requires that the auditee provide the Federal awards expended for each individual Federal program on the Schedule of Expenditures of Federal Awards (“Federal Schedule”). In accordance with 2 CFR 200.502, the determination of when a Federal award is expended, and thereby reported on the Federal Schedule, is generally based on when the activity related to the Federal award occurs. Condition: The Community Development Block Grant Cluster Entitlement/Special Purpose Grants award is a cost reimbursement based grant that reimburses award recipients for expenditures incurred on this program, which seeks to address health inequities faced by members of New York City’s (NYC) priority populations with HIV and was first granted in July 2024. The Association did not include the expenditures incurred under this grant on the Federal Schedule in 2024, resulting in an understatement of the entire amount of the grant expenditures incurred in the prior year of $237,306. This has been corrected by management and is included in the 2025 Federal Schedule. There was no impact to our prior year major program determination. The cumulative amount of expenditures under this award are included in the 2025 Federal Schedule. Cause: When this grant was initially awarded in mid 2024, the project was not identified in the system as being federally funded at the time of grant setup and was, therefore, inappropriately excluded from the 2024 Federal Schedule. Effect: Failure to properly identify this grant as a federal award resulted in the underreporting of federal expenditures incurred in 2024 by $237,306. Questioned Costs: None Recommendation: We recommend management enhance their controls around identification of federal grants at the time of grant setup as well as enhance completeness controls as part of the preparation and review of the Federal Schedule. Repeat Finding in the Prior Year: No Management’s Views and Corrective Action Plan: Refer to Management’s View’s and Corrective Action Plan at the end of the report after the summary schedule of prior audit findings and status.

Finding #2025-002 – Reporting – Significant Deficiency and Other Noncompliance. Applicable federal program: Department of Treasury, Passed through Harris County, Texas, Assistance Listing #: 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds, Contract Number: SLFRFP1966, Contract Year: 10/31/24 – 12/31/26. Criteria: Schedule of Expenditures of Federal Awards (SEFA) – 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Section 200.203 requires recipients and subrecipients of federal funds to establish, document, and maintain effective internal controls over federal awards. Section 200.510 (b) requires the auditee to 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. Condition and context: MAM incurred qualifying construction expenditures that were properly recorded as CIP. However, MAM did not record government grant revenue or a related grants receivable for the qualifying expenditures incurred during the fiscal year and did not identify or include the qualifying expenditures incurred during the fiscal year on the SEFA. Cause: MAM does not have a system sufficient to ensure that all qualifying federal expenditures are captured and reported to ensure completeness and accuracy of expenditures reported on the SEFA. Effect: Failure to adequately establish and maintain a system of internal controls over preparation of the SEFA adversely affected MAM’s ability to correctly identify and summarize federal awards for reporting in accordance with the Uniform Guidance. Recommendation: Develop policies and procedures to identify and reflect all federal programs on the SEFA, reconcile the federal expenditures to the federal program revenue on a routine basis, and formalize the independent review process for the SEFA and grant billings. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS – ALL FEDERAL PROGRAMS 2025-001 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the City of South St. Paul, Minnesota (the City) prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2025, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the City did not have sufficient controls in place to ensure the accurate preparation of the SEFA in compliance with this requirement. The City’s SEFA for fiscal 2025 was overstated by $749,656 in federal expenditures, due to the inclusion of costs that were incurred in the previous fiscal year. Questioned Costs – None. The 2025 SEFA was corrected when the misstatement was identified during the audit, and this would not have changed the determination that a Single Audit of federal awards expenditures was required for the 2024 fiscal year and would not have changed the risk assessment and major program testing for the 2024 fiscal year. Context – The City’s SEFA presented for audit for the year ended December 31, 2025 included $749,656 in two programs that should not have been included in this fiscal year. Cause – This was an oversight by city personnel. Repeat Finding – This is a current year finding. Effect – An inaccurate SEFA could result in incorrect major program determination for the Single Audit and could be considered a violation of federal award agreements. Recommendation – We recommend that the City review its internal control procedures over reporting and verify accuracy of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The City agrees with the finding. The City has separately issued a Corrective Action Plan related to this finding.

Assistance Listing Number, Federal Agency, and Program Name - ALN 15.916, Department of the Interior, Outdoor Recreation Acquisition, Development and Planning, Outdoor Recreation Acquisition, Development and Planning Grants, and ALN 66.468, Environmental Protection Agency, Drinking Water State Revolving Fund. Federal Award Identification Number and Year - All grants under ALN Pass through Entity - ALN 15.916, Colorado Department of Natural Resources, and ALN 66.468, Colorado Water Resources and Power Development Authority Finding Type - Material weakness Repeat Finding - Yes 2024 002 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 Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program 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 Outdoor Recreation Acquisition, Development and Planning program expenditures of $1,250,000 were omitted. The Drinking Water State Revolving Fund program was overstated by $76,884. 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 was adjusted for two federal programs. This did impact major program determination for Outdoor Recreation Acquisition, Development and Planning. Recommendation - We recommend the City ensure the effectiveness of controls to ensure expenditures reported on the SEFA are complete and accurate. Views of Responsible Officials and Corrective Action Plan - The Finance Department recently hired a new Grants Manager after being without this critical position for almost a year. The Grants Manager, along with the Grant Specialist and the Financial Reporting team accountants, plan to work together to improve the tracking and reconciliation of grant activity. In addition, the City implemented eCivis Euna Grants, a grant application, tracking, and reporting system, in November of 2025. The Grants Team will be working with Departments to document the grants process formally for the City and this will ensure that all grants are accounted for and tracked in the Euna grants system. This renewed capacity and new initiatives, supported by the new administrative cost recovery framework and the City's grants management platform, reflects a broader commitment to managing external funding with the same discipline applied to locally generated revenues.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS – ALL FEDERAL PROGRAMS 2025-002 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the City prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2025, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the City did not have sufficient controls in place to ensure the accurate preparation of the SEFA in compliance with this requirement. The City’s SEFA for fiscal 2025 was overstated by $147,700 in federal expenditures due to the inclusion of costs that were incurred in the previous fiscal year. Questioned Costs – None. The 2025 SEFA was corrected when the misstatement was identified during the audit, and this would not have changed the determination that a Single Audit of federal awards expenditures was not required for the 2024 fiscal year. Context – The City’s SEFA presented for audit for the year ended December 31, 2025 included $147,700 in one program that should not have been included in this fiscal year. Cause – This was an oversight by city personnel. Repeat Finding – This is a current year finding. Effect – An inaccurate SEFA could result in incorrect major program determination for the Single Audit and could be considered a violation of federal award agreements. Recommendation – We recommend that the City review its internal control procedures over reporting and verify accuracy of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The City agrees with the finding. The City has separately issued a Corrective Action Plan related to this finding.

Finding No. 2025 - 001: Federal Agency: Department of Health and Human Services Federal Program Title: Prevention of Disease, Disability, and Death through Immunization and Control of Respiratory and Related Diseases Federal Assistance Listing Number: 93.083 Award Period: January 1, 2025 through December 31, 2025 Pass-through Entity: Council of Medical Specialty Societies ("CMSS") Federal Award Identification Number and Year: Subaward No. 101 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria In accordance with 2 CFR 200.510 (Financial Statements), an 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 The Organization had revisions to the SEFA and management’s review and approval process did not detect the following errors that were identified during the audit procedures performed: An incorrect de minimis indirect cost rate was used and charged to a federal award. Approximately $65,000 of federal expenditures were omitted from the initial SEFA. Subrecipient costs from the prior year were charged to the current year due to incomplete accruals in the prior year. As a result, the SEFA was not complete or accurate prior to submission for audit. Cause The Organization’s internal controls over the preparation and review of the SEFA were not operating effectively. Effect or Potential Effect Inadequate controls over the preparation of the SEFA could result in financial misstatements or potential noncompliance. Questioned Costs N/A Identification as a Repeat Finding This finding 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 the Responsible Officials Management concurs with the finding and related recommendation. While the Organization completed its federal award activity in May 2025 and does not currently anticipate additional federal award activity, it recognizes the importance of compliance with grant reporting requirements, including the accurate preparation of the Schedule of Expenditures of Federal Awards. In response to this finding, the Organization has enhanced its procedures for determination of the appropriate indirect cost and strengthened its internal controls by implementing additional review and approval processes over grant expense reporting. These improvements, particularly in the review and approval functions, are designed to promote the timely and accurate reporting of grant activity, including SEFA preparation, should the Organization be subject to Single Audit requirements in the future. The Organization further has initiated repayment of indirect costs reported pursuant to the incorrect de minimis indirect cost rate, to the primary awardee.

Significant Deficiency/Noncompliance – Other 2 CFR §200.510(b) 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 §200.502 Basis for determining Federal awards expended. At a minimum, the schedule must: a. List individual federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. For example, the National Institutes of Health is a major subdivision in the Department of Health and Human Services. b. 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. c. Provide total Federal awards expended for each individual Federal program and the Assistance Listing Number or other identifying number when the Assistance Listings information is not available. For a cluster of programs also provide the total for the cluster. d. Include the total amount provided to subrecipients from each Federal program. e. For loan or loan guarantee programs described in §200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. f. Include notes that describe that significant accounting policies used in preparing the schedule, and note whether or not the auditee elected to use the 15% de minimis cost rate as covered in §200.414. The County prepared a SEFA that contained numerous errors affecting multiple federal programs. During the audit, we identified adjustments necessary to properly report federal expenditures, including corrections to amounts reported under several federal awards. Management posted audit adjustments to correct the schedule. The aggregate effect of these adjustments was material to the SEFA. The following adjustments were made to the federal programs: Program Assistant Listing Number Adjustment Snap Cluster 10.561 $ (752,663) Edward Byrne Memorial Justice Assistance Grant Program 16.738 (85,660) Federal Transit Cluster 20.507 and 20.526 (93,774) CCDF Cluster 93.575 (145,334) Temporary Assistance for Needy Families 93.558 (1,793,257) Foster Care Title IV-E 93.658 745,981 John H. Chafee Foster Care Program for Successful Transition to Adulthood 93.674 90,437 Social Services Block Grant 93.667 (642,471) Elder Abuse Prevention Interventions Program 93.747 (1,929) Medicaid Cluster 93.778 (1,095,261) Without effective controls over SEFA preparation, federal expenditures may be improperly reported. As a result, the SEFA initially submitted for audit was misstated and required significant audit adjustment. Inaccurate SEFA reporting could affect federal oversight, management decision-making, and the auditor's determination of major programs. We recommend the County review/update their current policies and procedures, including, prior to submitting the federal schedule to the auditors, a second review of data, support and amounts be reported, to help ensure accurate information is provided.

#2025-006 – Major Federal Award Finding – Federal Grants Management Nature of Finding: Federal Grants Management – Preparation and Maintenance of Schedule of Expenditures of Federal Awards Compliance Finding and Significant Deficiency in Internal Controls over Compliance This is a repeat of prior year #2024-007. Criteria/Condition: Per 2 CFR 200.510(b), 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. For SEFA reporting, the components of the SEFA were not accurately maintained. Cause/Context: While the Organization has a policy related to grant administration and tracking of expenditures, the procedures and controls relating to the policy were not properly implemented during 2025 to ensure a complete and accurate auditee-prepared SEFA. Effect: Expenditures for the Coronavirus State and Local Fiscal Recovery Funds grants were not accurately reported on the auditee-prepared SEFA. The SEFA presented has been adjusted for these errors. Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA. Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management will tie the preparation of the Schedule of Expenditures of Federal Awards back to the contract tracker used to monitor each grant's period of performance and expenditure activity, ensuring the SEFA is built directly from, and reconciled to, that tracker before submission to the auditor.

Federal Grantor: U.S. Department of Commerce (Commerce), U.S. Department of Housing and Urban Development (HUD) Pass-Through Grantor: Missouri Department of Economic Development Federal Assistance Listing Number: 11.307, 14.228 Program Title: Economic Adjustment Assistance, Community Development Block Grants Pass-through Entity Identifying Number: 2019-LR-02 Award Year: 2025 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. The County has not implemented proper internal controls to ensure the completeness and accuracy of the SEFA. Condition: The SEFA reported by the County in the 2026 annual budget document contained errors in amounts of federal expenditures reported. The SEFA did not report $1,667,175 of expenditures under program 11.307 Economic Adjustment Assistance or $448,232 of expenditures under 14.228 Community Development Block Grants. Cause: The Community Development Block Grant funds are kept in a separate bank account and were not accounted for in the County’s accounting system. The Economic Adjustment Assistance funds were accounted for in the 30 (Misc.) Fund, which is used for pass-through funding that is distributed to outside entities, rather than in a separate fund. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2025. The SEFA initially reported less than $1 million of federal award expenditures, which is less than the threshold for a Uniform Guidance compliance audit to be required. However, after the additional federal award expenditures were discovered, additional audit procedures had to be performed to complete the compliance audit. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.

Criteria: Uniform Guidance (2 CFR §200.510(b)) requires the Schedule of Expenditures of Federal Awards (SEFA) to include, for each federal program, the amount provided to subrecipients from federal awards when the auditee passes federal funds through to another entity. 2 CFR 200.331 establishes the criteria for distinguishing subrecipients from contractors. Condition: The SEFA as originally prepared and presented to the auditors did not separately disclose amounts passed through to subrecipients for the major program. During audit procedures, the auditors made inquiry of management regarding the classification of certain disbursements. Upon that inquiry, management determined that a group of entities (representing 55% of the total major program expenditures) previously coded as vendors were subrecipients under 2 CFR 200.331. The SEFA was subsequently revised to separately identify these amounts on the face of the schedule. Total SEFA expenditures were unchanged by the revision. The same system classification failure caused an immaterial incorrect presentation in ALN 93.243 as well. (See also Finding 2025-002 regarding subrecipient monitoring deficiencies arising from the same misclassification.) Cause: Management did not have adequate procedures or controls in place to evaluate and document whether entities receiving federal funds met the Uniform Guidance definition of a subrecipient versus a contractor (vendor). As a result, certain entities were incorrectly classified as vendors, and the related pass-through expenditures were not identified as amounts provided to subrecipients for purposes of SEFA reporting. The condition was not detected by management or those charged with governance prior to auditor inquiry. Effect: Amounts provided to subrecipients were omitted from the SEFA for the major program above as well as ALN 93.243, resulting in incomplete reporting required under Uniform Guidance. The misclassification of subrecipients as vendors caused the SEFA to not accurately disclose pass-through activity and could impair the ability of federal agencies, pass-through entities, and other users of the SEFA to assess the extent of subrecipient relationships and related monitoring responsibilities. The SEFA was revised prior to issuance to correctly reflect amounts provided to subrecipients; accordingly, no misstatement remains in the schedule as issued. Recommendation: Management should establish and document procedures for evaluating each recipient of federal award funds to determine whether the relationship meets the Uniform Guidance criteria for a subrecipient or contractor prior to first payment is processed. In addition, management should implement formal review, with evidence of review retained, of the SEFA to ensure all subrecipient payments are properly identified, accumulated, and disclosed as amounts provided to subrecipients prior to issuance. Management’s Response and Corrective Action Plan is found on page 29-31.

Finding 2025-001 Material Weakness, Inaccurate Schedule Of Expenditures Of Federal Awards (The SEFA) Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance) provides guidance related to preparation and reporting of a SEFA. 2 CFR Section 200.100 identifies the required elements of the SEFA, and 2 CFR Section 200.510 specifically requires that the SEFA include information on each federal award expended during the year. The County is required to prepare a complete and accurate SEFA and to have a system of internal controls, the design and operation of which allows management or employees in the normal course of performing their assigned functions to prevent, or detect and correct, errors on a timely basis. Condition: The original SEFA was inaccurate, which led to a material error in the reporting of federal awards. The County incorrectly omitted the Federal Highway Planning and Construction Grant in the aggregate amount of $858,817, which affected the major program determination. Cause: The SEFA was inaccurate because the funds omitted from the SEFA originally were related to expenditures from several years ago that were obligated in 2025. Due to the time lag in the expenditures, the funds were inaccurately omitted. Effect: As a result of the errors, the SEFA was materially incorrect. Inaccurate identification of federal awards may also result in inaccurate identification of compliance requirements, risk assessments, major program determination, materiality determinations and reporting errors. Questioned Costs: None Context: N/A Identification As A Repeat Finding: N/A Recommendation: The County should strengthen its internal controls by enhancing their reconciliation process to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has created a corrective action plan for the finding. See the corrective action plan included in this report.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS – ALL FEDERAL PROGRAMS 2025-001 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the City of Plymouth, Minnesota (the City) prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2025, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the City did not have sufficient controls in place to ensure the accurate preparation of the SEFA in compliance with this requirement. The City’s original SEFA for fiscal 2025 was understated by $1,587,830 in federal expenditures due to the omission of a new federal grant award to the City. This was discovered subsequent to the issuance of the original SEFA and therefore required a restatement of the SEFA and testing of federal Assistance Listing Number 66.202 as a major federal program. Questioned Costs – None. The 2025 SEFA has been corrected when the misstatement was identified, and testing of the new program was completed. Context – The City’s SEFA presented for audit for the year ended December 31, 2025 was missing expenditures of $1,587,830 in one major program that should have been included in this fiscal year. Cause – This was an oversight by city personnel. Repeat Finding – This is a current year finding. Effect – An inaccurate SEFA resulted in an incorrect major program determination for the Single Audit which required a restatement of the SEFA and additional major program testing. Recommendation – We recommend that the City review its internal control procedures over reporting and verify accuracy of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The City agrees with the finding. The City has separately issued a Corrective Action Plan related to this finding.

Finding 2025-002 Identification of the federal program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Noncompliance and Significant Deficiency in internal controls over cutoff of expenditures reported on the schedule of expenditures and federal awards Criteria: 2 CFR 200.510(b) requires that the Schedule of Expenditures of Federal Awards (SEFA) present total Federal awards expended in the fiscal year. Condition: The Cooperative’s SEFA for the fiscal year ended December 31, 2025 included federal award expenditures related to the prior fiscal year, resulting in improper cut-off of expenditures reported. Cause: The entity did not have adequate controls in place to ensure that only expenditures incurred within the current fiscal year were included in the SEFA. Effect: The current year SEFA included prior year expenditures, resulting in an overstatement of the expenditures reported on the SEFA in the current year. Questioned costs: None Recommendations: The entity should implement and document procedures to ensure proper cut-off of federal award expenditures, including a review of supporting documentation to verify expenditures are recorded in the correct fiscal period prior to preparation of the SEFA. Additionally, management should perform a detailed review of the SEFA before submission to ensure completeness and accuracy. Views of responsible officials: Management understands and agrees with the finding. Management will ensure that appropriate controls surrounding cut-off of federal award expenditures are in place to comply with any future grants.

Documentation of Costs Claimed for Reimbursement and Cash Management Significant Deficiency in Internal Control Over Compliance; Noncompliance; Known Questioned Costs - Federal Program: Assistance Listing No. 10.719 - Infrastructure Investment and Jobs Act Firewood Bank Program Federal Agency: U.S. Department of Agriculture, Forest Service (direct award; no pass-through entity) Federal Award Identification: 22-DG-11132544-049 (federal award year 2022) and 25-DG-11132544- 082 (federal award year 2025); USDA Forest Service Firewood Bank Program grant agreements identified by the Organization as contract 049 and contract 082 Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles; Cash Management; Reporting Type of Finding: Significant deficiency in internal control over compliance; noncompliance; known questioned costs Known Questioned Costs: $64,969 (contract 049 and contract 082 combined; the Organization’s records do not allocate administrative cost claims between the two agreements) Criteria: 2 CFR 200.303 requires a non-federal entity to establish and maintain effective internal control over the federal award providing reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations and the terms and conditions of the award. 2 CFR 200.403 requires that costs charged to a federal award be necessary and reasonable, allocable to the award, adequately documented, and otherwise allowable under the cost principles in 2 CFR 200 Subpart E. 2 CFR 200.305(b) requires that payments made in advance of expenditures be limited to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the entity in carrying out the purpose of the approved program. 2 CFR 200.510(b) requires the auditee to prepare a schedule of expenditures of federal awards for the period covered by the audit. Condition: We identified the following related conditions, each arising from the concentration of the program’s administrative, accounting and monitoring functions in a single individual without documented independent review: (a) Costs claimed without supporting documentation. The Organization submitted requests to the two awards under Assistance Listing No. 10.719 totaling $170,700 for administrative costs for the year ended December 31, 2025. The Organization’s accounting records and supporting documentation substantiate administrative costs of $105,731 applicable to those awards. The remaining $64,969 was claimed, and reimbursed by the grantor, without supporting documentation. The personnel component of the administrative costs claimed was based on estimated allocations rather than records of work performed, as described in Finding 2025-004. (b) Federal funds drawn and unspent at year end. At December 31, 2025 the Organization held $15,735 of federal funds that had been drawn but not disbursed for program purposes. A subrecipient returned its award on December 22, 2025 and the funds were not re-granted until January 30, 2026. (c) Advance payments. The Organization received advance payments under the awards totaling $1,155,000 during the year ($300,000 received September 24, 2025; $500,000 received October 30, 2025; and $355,000 received December 10, 2025). No documented determination of the program’s immediate cash requirements supports the amount or the timing of these advances, and the Organization does not monitor the elapsed time between receipt of advanced funds and their disbursement for program purposes. (d) Preparation and review of program records. The log of amounts requested for reimbursement and amounts received, the monthly reconciliation of that log, and the schedule of expenditures of federal awards are prepared by the same individual who prepares the requests and records the related receipts in the general ledger. Neither the reconciliation nor the schedule is subject to a documented review by an individual independent of its preparation. Cause: The Organization administers the award with limited administrative staff and has not adopted written policies and procedures governing federal grant administration, including the documentation required to support costs claimed for reimbursement, the determination of immediate cash needs before requesting or accepting advance payments, and independent review of the reimbursement log, the monthly reconciliation and the schedule of expenditures of federal awards. Effect or Potential Effect: Costs of $64,969 were claimed and reimbursed without documentation supporting their allowability, and $15,735 of drawn funds remained unspent at year end. Amounts totaling $127,373, of which $64,969 relates to this program, were recorded as due to the grantor through an audit adjustment, and $15,735 was recorded as a refundable advance. A deficiency in internal control over compliance exists that is less severe than a material weakness, yet important enough to merit attention by those charged with governance. Context: All administrative cost reimbursement requests submitted under the awards for the year ended December 31, 2025 ($170,700), all three advance payments received ($1,155,000), and the year-end balance of drawn but undisbursed funds were examined in their entirety and compared to the Organization’s accounting records; no sampling was used. Known questioned costs of $64,969 represent 38 percent of the administrative costs claimed and 5.2 percent of total program expenditures of $1,244,996, and exceed the $25,000 threshold in 2 CFR 200.516(a)(3). Our tests of compliance did not disclose instances of noncompliance that are material to the program, and our opinion on compliance for the major federal program is unmodified. Recommendation: We recommend that the Organization: (1) submit requests only for costs incurred and documented at the date of the request, and retain the request, the expenditure listing and the underlying support together in a single referenced file with the allowability review evidenced by preparer and reviewer sign-off; (2) prepare and retain, for each advance requested or received, an analysis of the program’s immediate cash requirements supporting the amount and timing of the advance, and monitor the period between receipt and disbursement of advanced funds; (3) require documented review of the monthly reimbursement log reconciliation and of the schedule of expenditures of federal awards by an individual not involved in preparing requests or recording receipts; and (4) coordinate with the USDA Forest Service program contact regarding repayment or offset of the amount recorded as due to the grantor. Repeat Finding: No Views of Responsible Officials: Management agrees that reimbursement requests should be subject to a more structured review and that an individual who did not prepare the request should independently review the supporting documentation and costs claimed. Cash needs are currently discussed and assessed based on factors including the number and status of applications, anticipated award amounts, and the timing of expected payments. Going forward, management will document its cash requirement determination when preparing each federal cash draw request, including the factors considered and the amount determined to be needed.

Finding No. 2025-001 – Material Weakness in Internal Control over Financial Reporting Criteria Management is responsible for the preparation and fair presentation of the Institution’s financial statements in accordance with U.S. generally accepted accounting principles (“U.S. GAAP”) and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. Pursuant to 2 CFR § 200.510(a), the Institution is also responsible for preparing financial statements that reflect its financial position, changes in net assets, and, where appropriate, cash flows for the fiscal year audited. An effective financial reporting process includes maintaining accounting records and supporting documentation sufficient to appropriately recognize, measure, classify, and report significant transactions and account balances in accordance with U.S. GAAP on a timely basis. This process also includes appropriate review, reconciliation, and analysis procedures designed to support the completeness and accuracy of the financial information used in preparing the financial statements. Condition The Institution’s financial reporting and period-end closing process did not include sufficiently formalized and timely procedures for the reconciliation and analysis of significant account balances and for the identification, evaluation, and accounting of significant transactions and contractual arrangements in accordance with U.S. GAAP. As a result, significant audit adjustments and prior-period adjustments were required in connection with the preparation of the financial statements. The following financial statement areas and/or accounts were principally affected:  Cash and cash equivalents – Bank reconciliations were not consistently completed on a monthly basis, and evidence of management review was not available for certain reconciliations. Unreconciled differences and reconciling items without adequate supporting documentation were identified and adjusted during the year-end closing and audit process.  Accounts receivable, revenue, and deferred revenue – The Institution’s process for evaluating revenue recognition and related accounts receivable and deferred revenue was not sufficiently formalized to ensure that revenue was recognized in accordance with the applicable contractual and funding arrangements and U.S. GAAP. Certain amounts had been recognized entirely as revenue although a portion should have remained deferred as of year-end, requiring adjustments to revenue and deferred revenue. In addition, supporting accounts receivable records were not consistently analyzed and reconciled to the general ledger, and certain recorded receivable balances could not be adequately substantiated.  Accounts payable, accrued expenses, and prepaid expenses – The Institution’s process for identifying, analyzing, and reconciling accounts payable and accrued expenses as part of the period-end closing process was not sufficiently formalized. In addition, certain expenditures required further analysis to determine whether they represented current-period expenses, accrued obligations, or prepaid expenses based on the underlying contractual arrangements.  Property and equipment and leasehold improvements – The Institution’s process for evaluating the capitalization and classification of property and equipment and the estimated useful lives, depreciation, and amortization periods of property and equipment and leasehold improvements was not sufficiently formalized. Certain expenditures initially recorded as expenses required and certain leasehold improvements had been amortized over periods that did not appropriately consider the applicable lease terms. These matters resulted in significant currentyear adjustments and material prior-period adjustments to accumulated depreciation and net assets.  Leases and contributed use of facilities – The Institution did not have a sufficiently formalized process to timely identify, review, and evaluate significant lease and facility-use arrangements for appropriate accounting under U.S. GAAP, particularly arrangements with governmental entities providing for nominal or substantially below-market rent. Certain arrangements required adjustments during the year-end closing and audit process to appropriately recognize and present right-of-use assets and lease liabilities, contributed use of facilities, contribution revenue, and related expenses. These matters resulted in significant post-closing adjustments and material prior-period adjustments affecting multiple significant financial statement accounts and demonstrate that the Institution’s financial reporting and period-end closing controls were not sufficient to prevent, or detect and correct, material misstatements in the financial statements on a timely basis. Cause The conditions described above were primarily caused by the lack of sufficiently formalized accounting and period-end closing procedures to ensure the timely analysis, reconciliation, documentation, and review of significant account balances and transactions. In addition, the Institution’s financial reporting process did not provide for sufficient and timely U.S. GAAP accounting analysis and review of certain significant, nonroutine, or complex transactions and contractual arrangements. Effect The deficiencies described above, individually and in combination, created a reasonable possibility that a material misstatement of the Institution’s financial statements, including the related notes and disclosures, would not be prevented, or detected and corrected, on a timely basis. These deficiencies resulted in significant post-closing adjustments and material prior-period adjustments affecting multiple significant financial statement accounts. Questioned Costs None Recommendation We recommend that the Institution strengthen and formalize its accounting and financial reporting processes, including its monthly and year-end closing procedures, to support the preparation of complete, accurate, and timely financial statements in accordance with U.S. GAAP. Management should establish formal procedures that provide for the timely reconciliation and analysis of significant account balances and related subsidiary records, appropriate review and approval of reconciliations and period-end adjustments, and timely resolution of reconciling items and accounting differences. The Institution should also establish procedures to timely identify and evaluate significant, nonroutine, or complex transactions and contractual arrangements, including revenue arrangements, leases and facilityuse agreements, and significant capital expenditures, to determine the appropriate accounting treatment under U.S. GAAP. Management should assign appropriate responsibility and levels of review over the financial reporting and closing process and ensure that personnel involved in these activities have access to the accounting expertise necessary to identify and address significant U.S. GAAP matters on a timely basis. Corrective Action Initiated Subsequent to December 31, 2025, the Institution engaged an experienced certified public accountant to assist management in strengthening its accounting and financial reporting processes. This represents a positive step toward addressing the matters described above. As these enhanced procedures and controls were initiated subsequent to the year under audit, their effectiveness was not reflected in the Institution’s internal control environment during the year ended December 31, 2025. Accordingly, the Institution should continue to implement and monitor these measures and evaluate their effectiveness over an appropriate period of time in addressing the conditions underlying the material weakness. Management’s Response and Corrective Action Plan Management acknowledges the matters described in the finding and has initiated several actions to strengthen the Institution’s accounting, financial reporting, and period-end closing processes. Beginning in January 2026, the Institution added resources to its Finance Department to address the increased volume and complexity of its operations. These resources include a Chief Financial Officer, accounting staff, a purchasing agent, and a budget and compliance officer. The additional resources have also allowed management to further define responsibilities within the accounting function and strengthen review and oversight throughout the financial reporting process. During 2026, the Institution also implemented Sage Intacct, a new accounting and financial management platform with capabilities supporting financial reporting, bank reconciliations, grant management, fixed assets, purchasing, procurement, and other accounting functions. In connection with the implementation, management established a more structured month-end closing workflow, including closing checklists designed to standardize the procedures performed and facilitate timely review and completion of the closing process. With respect to bank reconciliations, management indicates that reconciliations were prepared during the year; however, personnel assignments and the volume of activity contributed to a backlog in completing certain reconciliations by year-end. Management expects that the additional Finance Department resources and revised month-end closing procedures will assist in improving the timeliness and review of the reconciliation process. Management agrees with the prior-period adjustment related to the depreciation and amortization of certain equipment and leasehold improvements and notes that the accounting treatment had been consistently applied during prior years. Management will incorporate additional procedures into its accounting policies to periodically evaluate asset classifications, estimated useful lives, lease terms, and related depreciation and amortization considerations. Management also acknowledges that the accounting for certain lease arrangements and the contributed or in-kind use of facilities involves specialized U.S. GAAP considerations that became more significant during the year. The Institution plans to incorporate procedures addressing these transactions into its accounting policies and procedures, including the evaluation of lease arrangements and in-kind transactions, and to provide appropriate technical accounting training and consultation to Finance Department personnel.-41- LEAP SOCIAL ENTERPRISE INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended December 31, 2025 SECTION II – FINANCIAL STATEMENTS FINDING, (Continued) With respect to revenue, deferred revenue, and accounts receivable, management notes that during the period from July through December 2025, the Puerto Rico Department of Education (“PRDE”) provided advances related to several schools. In addition, amendments to the Cartas Constitutivas for certain schools affected the timing of funding allocations and collections and increased the complexity of allocating and accounting for related revenues and expenses. Management will further formalize its procedures for evaluating and documenting the appropriate accounting for funding advances, receivables, deferred revenue, and related revenue recognition based on the terms and conditions of the applicable funding arrangements. The Institution is updating its policies and procedures manual to incorporate the recommendations described in this finding, with particular emphasis on period-end closing and reconciliation procedures, revenue recognition, leases, contributed or in-kind transactions, and other areas requiring specialized accounting analysis. Management also plans to provide technical training and obtain appropriate technical accounting assistance, as needed, to support the consistent application of these procedures. Management believes that the additional Finance Department resources, implementation of the new accounting platform, enhanced month-end closing procedures, updated policies and procedures, and continued technical training represent meaningful steps toward addressing the conditions described in this finding. Management will continue to monitor these measures and evaluate their effectiveness as they operate over time. Responsible Official: CPA Robert Cabello, CFO

Finding 2025-002 Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing No: 93.069, Public Health Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.510 requires that the “auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements. The schedule must include the total Federal awards expended as determined in accordance with Section 200.502.” Condition: The preliminary Schedule included $2,662,417 in expenditures that were not federal grant awards. The final Schedule was corrected. Cause: The Corporation’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. Part III – Federal Award Findings and Questioned Costs (continued) Context: Total expenditures included on the preliminary Schedule were $5,119,949 for the year ended December 31, 2025. Total federal expenditures on the final Schedule were $2,639,518. The preliminary schedule included $1,393,244 in expenditures related to state-based grant awards to support the Corporation’s poison control program. In addition, $1,269,173 in expenditures related to various state-based grant awards for other programs determined not to be federal awards and no longer reported on the Schedule. Identification as a repeat finding, if applicable: Not applicable. Recommendation: Management should design and implement internal controls to review new and existing awards and agreements to ensure federal awards are identified and expenditures of federal awards are accumulated for reporting on the Schedule. Views of responsible officials: Management agrees with the finding and will enhance internal controls over the grant management process to review and monitor grants awards and other agreements. Management will design and implement internal controls over the completeness and accuracy of the Schedule.

Finding number: 2025-004 (Material Weakness in Internal Control over Compliance and Instance of Noncompliance) AL number: 21.027 AL title: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal award identification number and year: California Department of Housing and Community Development 21-HK-17231, 21-HK-17171, 21-HK-17192, 23-HK-18055, 23-HK-18064, 23-HK-18079, 23- HK-18085, 23-HK-18090, County of Los Angeles ARPA funds awarded in 2022. Name of federal agency: U.S. Department of the Treasury Name of pass-through entity: California Department of Housing and Community Development, and County of Los Angeles Repeat finding: Yes Criteria: Per 2 CFR §200.510(b), the SEFA must include: - A list of individual federal programs by agency, including the Assistance Listing number. - The total federal awards expended for each program, including capital projects funded by federal grants. - Amounts passed through to subrecipients. - Outstanding balances for loan or loan guarantee programs. - Significant accounting policies used in preparing the SEFA. Condition: During our audit of the Schedule of Expenditures of Federal Awards (SEFA), we identified that the schedule prepared by management included the full amount of expenditures related to certain awards that included a mixture of Federal and state funds. This resulted in an overstatement of the Federal awards in the SEFA prepared by management, also resulting in a need for a restatement of the 2024 SEFA. The 2025 SEFA has been corrected and the corrected amounts are included in the accompanying schedule. Cause: Management did not sufficiently review the terms of the award documents nor identify the need to obtain additional information from its funders. Possible effect: An inaccurate SEFA could result in noncompliance with the Uniform Guidance and an incomplete Single Audit. Questioned cost: N/A SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Recommendation: We recommend that management: - Implement a reconciliation process to ensure that all federal expenditures are accurately captured in the SEFA. - Provide additional training for accounting personnel on federal reporting requirements. - Review all local government awards to determine whether Federal funds are a component of the contracts. - Review SEFA data for completeness and accuracy before submission. This should include crossreferencing to individual awards documents. Views of responsible officials: Management concurs with the recommendation. The Mission recognizes that accurate SEFA preparation begins with identification of federal funding when an award is received and cannot depend solely on a year-end exercise performed after transactions have already been recorded. Management will establish a federal award identification and reconciliation process connecting contract administration, accounting records, federal award information, and the final SEFA. Management plans to formalize an enhanced SEFA preparation and review process by December 31, 2026. Finance/Accounting will maintain a centralized award inventory identifying the awarding agency and pass-through entity, Assistance Listing number, period of performance, federal and nonfederal funding components, amounts passed through to subrecipients, outstanding loan or loan-guarantee balances when applicable, and the accounting policies used to prepare the SEFA. At least quarterly, Accounting will reconcile the inventory and cumulative federal expenditures to the general ledger, grant billing records, award agreements, and supporting schedules; differences will be investigated, resolved, and documented. Management also plans to complete a preliminary year-to-date SEFA review before year-end. As part of the immediate FY 2025 remediation, management will document the bridge from the prior SEFA to the final revised schedule; retain support for the funding classification of County Operating and Measure H amounts; reconcile the final SEFA to the general ledger and project schedules; and ensure related amounts and disclosures in the audit report are updated consistently. The additional implementation activities are described below: * Reviewing all new grant agreements and contracts to identify funding sources and determine the appropriate federal participation percentage. * Providing targeted training to accounting personnel regarding federal reporting requirements and awards with blended funding sources. * Establishing a secondary management review of the SEFA, including reconciliation of expenditures to underlying award agreements and supporting schedules.

2025-002: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Transportation (DOT), U.S. Department of the Treasury (Treasury) Pass-Through Grantor: Missouri Department of Transportation Federal Assistance Listing Number: 20.205, 21.027 Program Title: Highway Planning and Construction; Coronavirus State and Local Fiscal Recovery Funds Pass-through Entity Identifying Number: BRO-R002(046) Award Year: 2025 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. The County has not implemented proper internal controls to ensure the completeness and accuracy of the SEFA. This finding was noted in the prior audit for the years ended December 31, 2021 and 2020 as item 2021-001. Condition: The SEFA reported by the County in the 2026 annual budget document contained errors in amounts of federal expenditures reported. Discrepancies in amounts reported on the 2025 SEFA and amount supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it has been prepared. Reasons for discrepancies in individual programs varied. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2025. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.

2025-003 Schedule of Expenditures of Federal Awards Preparation (SEFA) Criteria: 2 CFR §200.510 requires non-Federal entities expending federal awards to prepare a complete and accurate SEFA that includes all Federal awards expended during the fiscal year. Condition: The Organization's SEFA materially understated Federal expenditures. During the audit, additional Federal reimbursements were identified and included, resulting in a material adjustment to the SEFA. Cause: Management's procedures for identifying, accumulating, and reporting Federal expenditures were not sufficient to ensure the SEFA was complete and accurate. Effect: A materially misstated SEFA could result in inaccurate reporting of Federal expenditures, affect the identification of major programs, and impair compliance with Uniform Guidance reporting requirements. Recommendation: We recommend that management strengthen its procedures for preparing and reviewing the SEFA by reconciling Federal expenditures to the general ledger, grant agreements, and reimbursement requests before the SEFA is finalized. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and plans to enhance its SEFA preparation and review procedures.

Finding 2025-001 – Schedule of Expenditures of Federal Awards (SEFA) Preparation Information on Federal Program(s) – US Department of Health and Human Services and US Department of Housing and Urban Development, 93.224/93.527 Health Center Program Cluster, 93.778 Grants to States for Medicaid, 14.267 Continuum of Care Program Criteria - In accordance with the Code of Federal Regulations (CFR) Section 200.510(b), non-federal entities must prepare a SEFA for the period covered by the entity’s financial statements, including the total federal awards expended for each individual program and the Assistance Listings number (ALN). For a cluster of programs, the non-federal entity must provide the cluster name and total for the cluster. Condition - During our review of the SEFA, errors were identified in ALN classification, completeness of federal expenditures, inclusion of nonfederal expenditures, inclusion of out of period expenditures, and identification and presentation of clusters. Cause - The Organization’s review of the SEFA was not conducted at a level of precision sufficient to identify and prevent errors in the SEFA preparation process. As a result, the SEFA was not prepared in accordance with the Code of Federal Regulations. Effect - The SEFA was not accurately or completely prepared. The omission of certain federal expenditures resulted in a major program not being identified in the original major program determination process. In addition, the use of inaccurate ALN classifications resulted in changes to the expenditures reported within one of the major programs. Questioned Costs – None Context - During our review of the SEFA, we identified multiple errors in the Organization’s presentation and reporting of federal expenditures. The Organization did not properly identify applicable federal program clusters, reported incorrect ALNs for two federal grants, included $33,847 of non-federal expenses as federal expenditures, excluded $924,673 of expenditures related to two federal grants, and reported $118,099 of expenditures related to four federal grants in the incorrect reporting period. These errors affected major program determination and reporting. Repeat Finding – No Recommendation - We recommend the Organization enhance its review controls over SEFA preparation to ensure the SEFA is accurately and completely prepared in accordance with the Code of Federal Regulations. Management’s review should be performed at a sufficient level of precision to identify and prevent errors prior to issuance. View of Responsible Officials - Management agrees that appropriate controls are necessary to ensure the SEFA is complete, accurate, and prepared in accordance with federal requirements. The SEFA process will include reconciliation of federal expenditures to the general ledger and grant records, verification of Assistance Listing Numbers (ALNs), identification of applicable program clusters, and confirmation that expenditures are reported in the proper reporting period.

Material Weakness/Noncompliance – Other 2 CFR §200.510(b) 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 §200.502 Basis for determining Federal awards expended. At a minimum, the schedule must: a. List individual federal programs by Federal agency. For a cluster of programs, provide the cluster name, list individual Federal programs within the cluster of programs, and provide the applicable Federal agency name. For R&D, total Federal awards expended must be shown either by individual Federal award or by Federal agency and major subdivision within the Federal agency. b. 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. c. Provide total Federal awards expended for each individual Federal program and the Assistance Listing Number or other identifying number when the Assistance Listings information is not available. For a cluster of programs also provide the total for the cluster. d. Include the total amount provided to subrecipients from each Federal program. e. For loan or loan guarantee programs described in §200.502(b), identify in the notes to the schedule the balances outstanding at the end of the audit period. This is in addition to including the total Federal awards expended for loan or loan guarantee programs in the schedule. f. Include notes that describe that significant accounting policies used in preparing the schedule, and note whether or not the auditee elected to use the 15% de minimis cost rate as covered in §200.414. During the audit, it was noted $2,897,918 in expenditures was not included in the unaudited SEFA. An adjustment was necessary to properly present the SEFA. Management posted the adjustment to the SEFA as presented. The aggregate effect of the adjustment was material to the program and SEFA. The County failed to properly report all federal expenditures spent during the year. Inaccurate completion of the SEFA could lead to inaccurate reporting of federal expenditures by the County and could jeopardize future federal funding. We recommend the County work with its departments to ensure all grant activity is properly included and a materially accurate Schedule is presented for audit. Furthermore, the County should reach out to various Ohio agencies to assist in determining Federal activity.

Finding: 2025-001. Insufficient Controls Over Monitoring Federal Expenditures and SEFA Preparation Federal Agency: Federal Highway Administration Pass-through Agency: Texas Department of Transportation Assistance Listing Number: 20.205 Federal Program Name: Highway Planning and Construction Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR §200.303 requires entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the awards. 2 CFR §200.501 requires a Single Audit when a non-Federal entity expends $1,000,000 or more in Federal awards during the current fiscal year (or $750,000 during the prior year). 2 CFR §200.510(b) requires the preparation of a complete and accurate Schedule of Expenditures of Federal Awards (SEFA). Applicable GAAP requires recognition of grant revenue and related receivables when allowable expenditures are incurred. Condition: The City incurred reimbursable federal expenditures in the prior year but did not submit reimbursement requests or record the related receivable and revenue. As a result, certain federal expenditures were omitted from the SEFA, and total federal expenditures were understated below the $750,000 threshold for a Single Audit in the prior year. Cause: Grant administration is decentralized across multiple departments, and formal controls were not in place to reconcile grant expenditures to reimbursement requests or to monitor total federal expenditures and review the SEFA for completeness. Effect: Grant revenue and related receivables were understated, and the prior year SEFA was incomplete. As a result, the City did not include this grant award in the Single Audit in the prior year as required by Uniform Guidance. Questioned costs: N/A Context: N/A Repeat finding reference: N/A Recommendation: The City should strengthen oversight of federal grant activity by implementing procedures to monitor federal expenditures and ensure the SEFA is complete and accurate. This may include centralizing grant oversight within the finance function or designating a responsible grant administrator. Procedures should include periodic reconciliations of grant expenditures to reimbursement requests and a formal year-end review of total federal expenditures and the SEFA, with coordination between the finance function and departments administering federal programs. Personnel involved in grant administration should receive training on Uniform Guidance requirements. View of Responsible Officials Management’s response and corrective action plan are included in the accompanying corrective action plan.

Condition: The City has not adopted procedures (controls) to ensure compliance with 2 CFR 200 regarding the preparation and completion of the schedule of expenditures of federal awards and the accompanying notes and disclosures required by Uniform Guidance. Criteria: 2 CFR 200.510(b) Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of Uniform Guidance. Effect of Condition: Effect is potential errors in reporting and preparation of the schedule of expenditures of federal awards which could cause non-compliance with 2 CFR 200. Recommendation: Adopt and implement procedures (controls) to become compliant with Uniform Guidance.

Finding 2025-001 Controls over Revenue Recognition and Review / Preparation of the SEFA Finding Type Significant deficiency in internal control over financial reporting, other matters compliance finding, and significant deficiency in internal control over compliance. Criteria Organizations should maintain internal control to provide for the recognition of revenue in accordance with the provisions of U.S. Generally Accepted Accounting Principles (GAAP). In addition, Section 200.510(b) of 2 CFR Part 200 (the Uniform Guidance) requires recipients of federal awards to prepare a complete and accurate schedule of expenditures of federal awards (SEFA). Condition and Context During the audit, upon management’s completion of the final SEFA reconciliations, it was determined that an adjusting entry was required in order to reduce recognized federal awards revenue in the financial statements and expenditures on the SEFA for the year ended September 30, 2025 by $407,237. Cause ASTHO did not timely complete its final reconciliation of total federal award revenue to total federal award expenses. Effect Had the error not been corrected, Federal award revenue and the SEFA expenditures would have been overstated by $407,237. Repeat Finding No. Recommendation We recommend that ASTHO implement a procedure to provide for the reconciliation of total federal award revenue to the total federal award expenses on a monthly basis. This should reduce the likelihood of similar future errors. Views of Responsible Officials and Planned Corrective Action See attached corrective action plan. Questioned Costs None.

Assistance Listing, Federal Agency, and Program Name 93.247 Advanced Nursing Education Grant Program Federal Award Identification Number and Year 22T96HP45839 Pass through Entity N/A Finding Type Material weakness Repeat Finding Yes Criteria Per 2 CFR Section 200.510(b), "the auditee" must create a Schedule of Expenditures of Federal Awards (SEFA) if they expend more than $1 million in federal awards during their fiscal year. The schedule of expenditures of federal awards should include all expenditures associated with federal grants during the fiscal year. Per 2 CFR 200.400(d), the accounting practices of the recipient and subrecipient must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the Federal award. Condition The Organization lacked effective controls over the review of the SEFA to ensure that only federal expenditures were included for fiscal year 2025 and to ensure that expenditures were appropriately tracked and recorded to the correct grant period. Questioned Costs N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed N/A Context The Organization lacked effective controls to ensure that expenditures were appropriately tracked to individual grants and recognized in the proper reporting period. Consequently, the original SEFA included nonfederal expenditures. Completeness testing identified approximately $120,000 of expenditures that did not pertain to current year federal awards, as well as approximately $65,000 of expenditures related to prior year activity that were inappropriately included on the SEFA. Cause and Effect The Organization does not have an award management system connected to its accounting software to appropriately track federal grants and their associated expenditures. This prevented the Organization from being able to implement effective controls to validate expenditures were applied to the proper grant in the proper period and to ensure that transactions were accounted for consistently between the financial statements and the SEFA. Recommendation We recommend that management implement procedures to perform a review at period end to ensure all payroll and accounts payable accruals are properly included on the SEFA and any amounts related to a future period (prepaid expenses) are excluded. We additionally recommend that management implement procedures to ensure only federal activity is reflected within the SEFA. Views of Responsible Officials and Planned Corrective Actions The Organization acknowledges certain errors in grant tracking and SEFA preparation resulting from the lack of an integrated award management system. The Organization will enhance its reviews around SEFA preparation and federal expenditure tracking to accommodate the lack of an integrated system as well as to ensure cut-off, completeness, and classification of federal expenditures.

Assistance Listing, Federal Agency, and Program Name - 93.045/93.053, Department of Health and Human Services, Aging Cluster Federal Award Identification Number and Year - N/A Pass through Entity - Area Aging on Aging 1C Finding Type - Material weakness Repeat Finding - No Criteria - Uniform Guidance at 2 CFR 200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately reports total federal expenditures for each federal program. In addition, effective internal control over compliance, as required by 2 CFR 200.303, requires controls that ensure expenditures reported on the SEFA are complete, accurate, and properly reconciled to underlying accounting records and amounts billed to the funding agency. Condition - The County did not maintain effective internal control over the reconciliation of expenditures reported on the Schedule of Expenditures of Federal Awards to amounts billed to the funding agency. If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - None Identification of How Questioned Costs Were Computed - N/A Context - The SEFA is a key component of the Single Audit and serves as the primary basis for determining major programs subject to audit under the Uniform Guidance. As part of the SEFA preparation process, management compiles federal expenditures from multiple sources, including underlying accounting records and amounts billed to funding agencies. Accurate reconciliation of these sources is critical to ensure that federal expenditures are reported completely and accurately, and that major program determinations are appropriately made. As a result of the audit, it was identified that expenditures related to the Aging Cluster were understated by approximately $126,000 on the preliminary SEFA due to the omission of expenditures that had been billed to the funding agency but backed out of amounts reported on the SEFA during the reconciliation process. Management recorded an adjustment to correct the understatement prior to issuance of the final SEFA. Cause and Effect - The County’s SEFA preparation process did not include a sufficiently designed and implemented control to ensure the accuracy of reconciling items between expenditures reported on the SEFA to amounts billed to the funding agency. As a result of this deficiency, expenditures in the Aging Cluster were understated by approximately $126,000 on the preliminary SEFA. The correction of this error on the final SEFA increased total expenditures for the Aging Cluster, resulting in the program being classified as a Type A program rather than a Type B program for major program determination purposes. Because the deficiency resulted in a material misstatement of the SEFA that was not prevented or detected by internal control, it is considered a material weakness in internal control over compliance. Recommendation - We recommend that management design and implement effective controls over the preparation of the SEFA, including maintaining adequate support for adjustments and reconciling items. Such controls should be performed and reviewed by personnel independent of the SEFA preparation process to ensure the completeness and accuracy of federal expenditures reported. Views of Responsible Officials and Planned Corrective Actions - The County has established procedures for reconciling general ledger activity to supporting documentation and Federal Financial Reports (FFRs/FSRs) throughout the fiscal year, including additional reconciliation procedures performed at year end to capture late or adjusting entries. The condition was further impacted by timing differences between departmental reporting and subsequent adjusting entries, as well as the aggregation of adjustments across multiple programs without sufficient program-level detail at the time of review. While follow-up was initiated to obtain supporting breakdowns, the process did not require resolution of these items prior to final classification and inclusion in year-end reporting. The County is strengthening internal controls over grant-related financial activity and SEFA preparation by enhancing and enforcing requirements for accurate transaction recording, supporting documentation, and independent validation. Key improvements include: • Enhanced documentation and classification requirements for grant-related entries • Strengthened review and validation controls to ensure proper support and classification • Improved reconciliation and adjustment protocols, including postreporting revalidation • Control enforcement and escalation for unsupported or unresolved items • Training and guidance on federal compliance requirements

Finding 2025-002 – Incomplete Subrecipient Agreements and Inaccurate Subrecipient SEFA Reporting Federal Program: Violence Against Women Formula Grants Assistance Listing Number: 16.588 Compliance Requirement: Subrecipient Monitoring Internal Control Deficiency: Material Weakness - Insufficient controls over subaward agreement content and subrecipient reporting oversight Compliance Finding: Subaward agreements missing required elements; subrecipient failed to report pass-through funds on its SEFA Questioned Costs: None Criteria: Under 2 CFR § 200.332, pass-through entities must ensure that all subaward agreements contain specific federal award information, monitoring expectations, and required terms and conditions. Subrecipients must report federal expenditures on their SEFA in accordance with 2 CFR § 200.510(b). Condition: During our testing of subrecipient monitoring and federal reporting, we noted that subrecipient agreements did not include several elements required under 2 CFR § 200.332(b), (c), and (e)–(i). Specifically, the agreements reviewed were missing one or more of the following required components: • Federal award identification information, including unique entity identifier (UEI), Federal Award Identification Number (FAIN), ALN, award date, and other required identifiers. • Required access-to-records language granting the pass-through entity, auditors, and federal agencies the right to access pertinent records. • Subaward-level closeout requirements, including timelines and documentation expectations. In addition, during compliance testing we noted that the subrecipient did not include the pass-through funds received in its own SEFA, resulting in incomplete federal expenditure reporting. Cause: The deficiencies appear to result from the absence of a standardized subaward agreement template and insufficient review procedures to ensure all Uniform Guidance elements are included. The subrecipient’s SEFA omission appears to stem from a lack of communication and monitoring regarding reporting requirements. Effect: Incomplete subaward agreements increase the risk that subrecipients may not understand federal requirements, may apply incorrect cost principles, or may fail to comply with federal terms. Missing SEFA reporting by the subrecipient results in inaccurate federal expenditure reporting and may affect federal oversight, risk assessments, and audit coverage.Recommendation: Management should implement a standardized subaward agreement template that incorporates all elements required under 2 CFR § 200.332. If any of the required elements are missing, adding a short federal award information/Uniform Guidance appendix and an explicit records-access and closeout article would bring the contracts into compliance. Management should also strengthen monitoring procedures to ensure subrecipients understand and comply with SEFA reporting requirements, including verifying that pass-through funds are properly reported. Management’s Response and Corrective Action Plan is found on page 28-29.

Finding 2025-001 – Accuracy of Schedule of Expenditures of Federal Awards (SEFA) Compliance Requirement: Reporting Internal Control Deficiency: Significant Deficiency - Insufficient review over SEFA preparation Compliance Finding: SEFA reported incorrect Assistance Listing Numbers (ALNs) Questioned Costs: None Criteria: Per 2 CFR 200.510(b), auditees must prepare a SEFA that accurately identifies federal programs by the correct ALN. Condition: The SEFA submitted for the audit included incorrect ALNs for certain federal programs which misidentified a Type A program and omitted a major program. Cause: The errors appear to have resulted from inadequate procedures to verify ALNs against federal award documentation during SEFA preparation. Effect: Incorrect ALNs may result in inaccurate identification of federal programs and increase the risk of misidentification in major program determination, potentially affecting audit scope and compliance conclusions. Recommendation: Management should implement procedures to verify that ALNs reported on the SEFA agree to authoritative federal award documentation prior to finalization. Management’s Response and Corrective Action Plan is found on page 28-29.

Finding Number: 2025-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 11131-028 Award Year: 10/01/2024 – 09/30/2025 Government Department/Agency: Office of the State Superintendent of Education (OSSE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Federal Funding Accountability and Transparency Act (FFATA) Reporting Compliance: In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS) or System for Award Management (sam.gov) website from March 8, 2025 onwards. FFATA reports are submitted no later than the month following the month in which this Federal award is made, and annually after that. In accordance with the requirements of 2 CFR Section 1402.300(b), the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR Part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR Part 170 Reporting Subaward and Executive Compensation Information. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, 2 CFR Section 200.510(b) states 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 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – For one (1) subaward sample selected for FFATA testing, we noted that OSSE failed to submit the FFATA report within the required timeframe. Transactions tested - 8 Subaward not reported - 0 Report not timely - 1 Subaward amount incorrect - Not applicable – subaward amount was correct. Subaward missing key elements - Not applicable – no missing key elements. Dollar amount of tested 2025 subawards - $8,900,559 Subaward not reported - $ - Report not timely - $ 38,487 Subaward amount incorrect - Not applicable – subaward amount was correct. Subaward missing key elements - Not applicable – no missing key elements. Additionally, during our testing of the SEFA, we noted that OSSE incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2025, OSSE incurred $25.7 million in subrecipient expenditures for this program and incorrectly reported that there were no subrecipient expenditures on the preliminary SEFA. While the subrecipient expenditure amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of OSSE’s compliance with reporting requirements. Effect – Failure to properly submit the FFATA report and failure to properly review and present expenditure can result in noncompliance with reporting requirements. Cause – OSSE did not have proper internal controls and policies and procedures in place to fulfill the FFATA reporting requirements. In addition, OCFO did not comply with their policies and procedures to ensure accuracy of the SEFA. Recommendation – We recommend that OSSE evaluate its Transparency Act reporting control procedures and update them as necessary to ensure they promote compliance with the Federal regulations. These procedures should include a supervisory review of the report to be submitted timely. In addition, we recommend that OCFO adhere to instituted policies and procedures to ensure accuracy of the SEFA. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – OSSE concurs with the auditor’s finding and recommendations related to this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.

Finding Number: 2025-024 Prior Year Finding Number: 2024-030 Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Opioid STR ALN: 93.788 Award #: Various Award Years: 09/30/2022 – 09/29/2025 09/30/2024 – 09/29/2027 Government Department/Agency: Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Federal Funding Accountability and Transparency Act (FFATA) Reporting Compliance: In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS) or System for Award Management (sam.gov) website from March 8, 2025, onwards. FFATA reports are submitted no later than the month following the month in which this Federal award is made, and annually after that. In accordance with the requirements of 2 CFR Section 1402.300(b), the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR Part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR Part 170 Reporting Subaward and Executive Compensation Information. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, 2 CFR Section 200.510(b) states 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 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FFATA Reporting Compliance: During our testing of FFATA reporting, it was noted that reports were submitted late by the DBH program management due to staffing shortage. The FFATA reporting for all nine subawards selected for testing was submitted late, i.e., beyond the deadline of within 30 days of the subaward or subaward modification date. • SEFA Reporting Compliance: During our testing of the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2025, DBH incurred $12.4 million in subrecipient expenditures for this program and incorrectly reported $11.7 million subrecipient expenditures on the preliminary SEFA. While the subrecipient expenditure amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure timely reporting and that correct amounts were reported and were properly reviewed as it relates to the Opioid STR program: • FFATA Reporting Compliance: Failure to submit FFATA reports within the deadline of 30 days of the subaward or subaward modification date results in noncompliance for the DBH program. • SEFA Reporting Compliance: The effect of the condition is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that FFATA reports were submitted timely and the amounts on the SEFA were properly reported. Recommendation – We recommend the following: • FFATA Reporting Compliance: We recommend DBH to strengthen its internal control and procedures to ensure submission of FFATA reports within the deadline of 30 days of the subaward or subaward modification date. • SEFA Reporting Compliance: We recommend DBH to ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review existing policies and procedures for preparing the SEFA to ensure that it is complete and accurate. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – The DBH Office of the Chief Financial Officer (OCFO) concurs with this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.

Finding Number: 2025-026 Prior Year Finding Number: 2024-036 Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Block Grants for Substance Use Prevention, Treatment, and Recovery Services ALN: 93.959 Award #: Various Award Years: 10/01/2022 – 09/30/2025; 09/01/2021 – 09/30/2025; 03/15/2021 – 03/14/2025 Government Department/Agency: Department of Behavioral Health (DBH) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Federal Funding Accountability and Transparency Act (FFATA) Reporting Compliance: In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS) or System for Award Management (sam.gov) website from March 8, 2025, onwards. FFATA reports are submitted no later than the month following the month in which this Federal award is made, and annually after that. In accordance with the requirements of 2 CFR Section 1402.300(b), the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR Part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR Part 170 Reporting Subaward and Executive Compensation Information. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, 2 CFR Section 200.510(b) states 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 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of the reporting compliance requirement, we noted the following: • FFATA Reporting Compliance: During our testing of FFATA reporting, it was noted that reports were submitted late by the DBH program management due to staffing shortage. The FFATA reporting for all four subawards selected for testing was submitted late, i.e., beyond the deadline of within 30 days of the subaward or subaward modification date. • SEFA Reporting Compliance: During our testing of the SEFA, we noted that DBH incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2025, DBH incurred $1.2 million in subrecipient expenditures for this program and incorrectly reported $1.4 million subrecipient expenditures on the preliminary SEFA. While the subrecipient expenditure amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of DBH’s compliance with specified reporting requirements using a statistically valid sample. Effect – Without proper internal controls and policies and procedures in place to ensure timely reporting and that correct amounts were reported and were properly reviewed as it relates to the Block Grants for Substance Use Prevention, Treatment, and Recovery Services program: • FFATA Reporting Compliance: Failure to submit FFATA reports within the deadline of 30 days of the subaward or subaward modification date results in noncompliance for the DBH program. • SEFA Reporting Compliance: The effect of the condition is that the SEFA was not accurately prepared. Cause – Management did not have proper internal controls and policies and procedures in place to ensure that FFATA reports were submitted timely and the amounts on the SEFA were properly reported. Recommendation – We recommend the following: • FFATA Reporting Compliance: We recommend DBH to strengthen its internal control and procedures to ensure submission of FFATA reports within the deadline of 30 days of the subaward or subaward modification date. • SEFA Reporting Compliance: We recommend DBH to ensure that agency personnel receive proper training on subrecipient versus vendor determination; as well as review existing policies and procedures for preparing the SEFA to ensure that it is complete and accurate. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – The DBH Office of the Chief Financial Officer (OCFO) concurs with this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.

Finding Number: 2025-027 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Homeland Security COVID-19 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) ALN: 97.036 Award #: Various Award Year: 10/01/2024 – 09/30/2025 Government Department/Agency: Homeland Security and Emergency Management Agency (HSEMA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 200.302(a), Financial Management, states that each state must expend and account for the federal award in accordance with state laws and procedures for expending and accounting for the state’s own funds. In addition, the state’s and the other non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. Schedule of Expenditures of Federal Awards (SEFA) Reporting Compliance: Requirements, Cost Principles, and Audit Requirements, 2 CFR Section 200.510(b) states 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 200.502. While not required, the auditee may choose to provide information requested by Federal awarding agencies and pass-through entities to make the schedule easier to use. Condition – During our testing of federal reporting and the Schedule of Expenditures of Federal Awards (SEFA), we noted that the cumulative federal expenditures reported on two (2) quarterly Federal Financial Report (SF-425) did not reconcile the total expenditures claimed on the SEFA for the life of the award. Specifically, the SF-425 submitted for the period ended September 30, 2025 reported a cumulative total of approximately $924 million, whereas the SEFA recorded lifetime expenditures of approximately $1.051 billion, resulting in an unreconciled variance of approximately $127 million. Additionally, during our testing of the SEFA, we noted that HSEMA incorrectly reported the value of subrecipient expenditures included within the subrecipient expenditure column. For the year ended September 30, 2025, HSEMA had a negative $0.7 million in subrecipient expenditures for this program and incorrectly reported $37.9 million subrecipient expenditures on the preliminary SEFA. While the subrecipient expenditure amount was not accurate, the total expenditures amount was accurately reported. The error in the subrecipient expenditures amount was subsequently identified and corrected as a result of the audit process. Questioned Costs – None. Context – This is a condition identified per review of HSEMA’s compliance with reporting requirements. Effect – Failure to properly review and present expenditures can result in noncompliance with reporting requirements. Cause – HSEMA did not comply with their policies and procedures to ensure accuracy of the SEFA and other reports necessary to meet compliance requirements. Recommendation – We recommend that HSEMA adheres to instituted policies and procedures to ensure the accuracy of the SF-425 and the SEFA. Related Noncompliance – Material noncompliance. Views of Responsible Officials and Planned Corrective Actions – HSEMA agrees with the conditions and recommendations of this finding. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section.

Finding No.: 2025-004 Federal Agency: Medicaid Cluster (93.778) Criteria Under 2 CFR §200.510(b), nonfederal entities that expend federal awards are required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity’s financial statements. The SEFA must: • Include total federal expenditures for each federal program • Identify each federal program by Assistance Listing Number (ALN) • Include the name of the federal agency and pass-through entity, where applicable • Include pass-through identifying numbers • Disclose significant accounting policies used in preparing the SEFA • Reconcile, or be traceable, to the underlying accounting records Additionally, Government Auditing Standards require that internal controls over financial reporting and compliance be designed and implemented to ensure accurate reporting. Conditions Found The Organization did not prepare a complete and accurate SEFA for the year ended September 30, 2025. Certain federal expenditures were initially omitted from the SEFA. As a result, the SEFA required adjustment which resulted in a second major program for testing once the Organization corrected its SEFA. Cause The condition appears to be the result of inadequate internal controls over the identification, tracking, and reporting of federal awards. Specifically: • Lack of a formal process to identify all federal funding sources • Insufficient review controls over SEFA preparation • Limited understanding of SEFA reporting requirements under Uniform Guidance Effect The incomplete SEFA increases the risk that: • Federal expenditures may be understated or misstated • Major program determination could be impacted • Required disclosures under Uniform Guidance may not be met • Users of the financial statements may rely on inaccurate information Questioned Costs The Organization’s expenditures are similar amongst all programs and grants. At the onset of the audit, expenditures were not coded and reconciled to each grant individually; however, the Organization was able to identify, code and update the general ledger to properly identify the major program expenditures. We were able to determine there are no questioned costs. Context The SEFA omitted approximately $347,000 in federal expenditures in their SEFA provided during audit planning procedures, representing approximately 18% of total federal expenditures. Repeat Finding No Recommendation We recommend that the Organization strengthen internal controls over SEFA preparation and completeness by: • Implementing a comprehensive process to identify all federal awards, including pass-through funding • Maintaining a centralized listing of federal grants with ALNs and award information • Ensuring expenditures are tracked by federal program throughout the year • Performing a detailed review and reconciliation of the SEFA to the general ledger prior to issuance • Providing training to personnel responsible for SEFA preparation on Uniform Guidance requirements Views of Responsible Officials See attached corrective action plan.

Finding 2025-003: Significant Deficiency – SEFA reporting Federal grantor: All Federal Programs Condition: The SEFA was not complete and contained reporting errors. Specifically, the grant contract amendment numbers and award amounts reported in SEFA were inaccurate. Criteria: Per 2 CFR § 200.510(b), the SEFA must include a complete and accurate listing of federal awards expended during the fiscal year. Information reported in the SEFA should agree to supporting grant documentation and underlying accounting records. Cause: The issues appear to result from a lack of comprehensive review and reconciliation procedures during SEFA preparation. Effect: Inaccurate SEFA reporting results in noncompliance with Uniform Guidance requirements and increases the risk of errors in federal reporting, incorrect identification of federal awards, and inaccurate major program determination. Recommendation: CFILC should strengthen internal controls over SEFA preparation by implementing a formal review and reconciliation process to verify grant contract amendment numbers, award amounts, and other key grant information to executed grant agreements and supporting documentation prior to issuance. Response: CFILC agrees with the finding and is implementing enhanced review procedures to ensure the accuracy and completeness of SEFA reporting going forward.

Assistance Listing, Federal Agency, and Program Name 93.889, U.S. Department of Health and Human Services, National Bioterrorism Hospital Preparedness Program Federal Award Identification Number and Year DKT3LLBWFVL3 - 2025 Pass through Entity North Carolina Department of Health and Human Services Finding Type Material weakness Repeat Finding No Criteria WakeMed is responsible for identifying in its accounting records all federal awards received and expended and the federal programs under which they were received, including the Assistance Listing title and number, federal award identification number, award year, and federal agency or pass through entity, as applicable, in accordance with 2 CFR § 200.302(b)(1). In addition, 2 CFR § 200.510(b) requires WakeMed to prepare a schedule of expenditures of federal awards for the period covered by the financial statements that includes total federal awards expended and identifies individual federal programs by federal agency, including applicable Assistance Listing Numbers and pass through identifying information. Under 2 CFR § 200.331, the substance of the relationship is more important than the form of the agreement, and each agreement should be evaluated to determine whether the entity is acting as a subrecipient or contractor. Condition Management did not initially identify a contract with an awarding agency as a federal subaward, which resulted in ALN 93.889 being omitted from the SEFA. The amount was subsequently added to the SEFA. Questioned Costs N/A If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed N/A Context Management incorrectly identified that they were a contractor of funds received from the North Carolina Department of Health and Human services under ALN 93.889 rather than a subrecipient. As a result, the schedule of expenditures of federal awards reported for the year ended September 30, 2025 did not originally have this grant included and was understated by $485,737. Cause and Effect Controls in place did not ensure the SEFA was complete and accurate. The lack of controls resulted in an understatement of the schedule of expenditures of federal awards for the year ended September 30, 2025. There was no impact to major program determination for the year ended September 30, 2025. Recommendation Management should implement a process to ensure appropriate identification for agreements in which they are considered a subrecipient vs a contractor. Views of Responsible Officials and Corrective Action Plan Management concurs with the finding and has implemented a new grant governance committee and process for identifying grant components before entering into grant agreements. Management also created a new grant department with staff devoted to researching, applying for, monitoring, and reporting on all grants. The accounting function for grants will be done by this team as well but with continued oversight by the Executive Director, Accounting.

Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2025-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2024-001) Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee's financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended September 30, 2025, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to a lack of capacity in the finance department and not following the year-end closing schedule. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: Management should address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Questioned costs: None Responsible Official's Response: We agree with the auditors’ comments, the following action will be taken to address the situation. As Semcac continues to grow and compliance requirements increase, we have evaluated staffing capacity within the Fiscal Department and added a management-level position in fiscal year 2026. Semcac has also contracted with an outsourced accounting firm to strengthen internal controls, improve processes and procedures, support adherence to the year-end closing schedule, and help ensure timely submission of the audit reporting package.

2025-001: SEFA Reporting Significant Deficiency - Ryan White HIV/AIDS Program Parts A and B Federal Agency: Department of Health and Human Services Pass-through Entity: New York City Department of Health and Mental Hygiene Program: Ending the HIV Epidemic: A Plan for America — Ryan White HIV/AIDS Program Parts A and B Assistance Listing #: 93.686 Grant Period: 3/1/21-2/28/26 Criteria OMB Uniform Guidance 2 CFR 200.510(b)(3) requires that the auditee provide the Federal awards expended for each individual Federal program on the Schedule of Expenditures of Federal Awards (“SEFA”). In accordance with 2 CFR 200.502, the determination of when a Federal award is expended, and thereby reported on the SEFA, is generally based on when the activity related to the Federal award occurs. Condition The Ryan White HIV/AIDS Program Parts A and B grant is a cost reimbursement based grant that reimburses award recipients for expenditures incurred on this program, which seeks to address health inequities faced by members of New York City’s (NYC) priority populations with HIV and was first granted in March 2021. Sunset Park has not included the expenditures incurred under this grant on the SEFA until FY2025 when it was first identified. As a result, the expenditures reported by Sunset Park on its SEFA from 2021-2024 were understated by the entire amount of the grant’s expenditures incurred in each respective year. This has been corrected by management in the 2025 SEFA included in this report. There was no impact to our prior year audit scoping given the expenditures in each respective year would not have changed the prior determination of major programs. The cumulative amount of expenditures under this award was included on the 2025 SEFA and included as a major program. Cause When this grant was initially awarded in early 2021, the Assistance Listing Number (ALN) was not identified at the time of grant setup, therefore, the award wasn’t identified as a federal award. During the annual preparation of the SEFA in the subsequent years, the award was omitted from the SEFA due to the fact that it was not identified as a federal grant within the grant listings. Effect Failure to properly identify this grant as a federal award resulted in the underreporting of federal expenditures incurred from 2021 through 2024 by $1,267,956. This was corrected in the 2025 SEFA included in this report, as such the entire cumulative expenditure amount previously underreported was reported in the current year SEFA. The major program determination and audit scoping for the 2025 audit resulted in this award being selected for testing as a major program. If the expenditures had been properly reported in each respective year’s SEFA, the major program determination and audit scoping would not have been impacted. This is not a repeat finding. Questioned Costs None Recommendation We recommend Sunset Park enhance their controls around identification of federal grants at the time of grant setup as well as enhanced completeness controls as part of the preparation and review of the SEFA. Management’s Views and Corrective Action Plan Refer to Management’s View’s and Corrective Action Plan at the end of the report.

Criteria: In accordance with 2 CFR section 200.510(b) (Uniform Guidance), “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. The schedule must include the total Federal awards expended as determined in accordance with § 200.502.” Condition: The College did not have controls in place to ensure the Schedule of Expenditures of Federal Awards (SEFA) was accurately reconciled with the general ledger. As a result, there were discrepancies between the amounts reported on the SEFA and the actual expenditures in the College’s accounting records. Cause: The College does not have a process in place to reconcile the SEFA to the general ledger to ensure accurate records. Expense entries (expenditures) are posted by several people across the campus when funds are spent. Revenue entries (drawdowns) are posted by the business office, however there is no process to ensure these drawdowns are the same as the amounts expended. Revenue is also not deferred to the appropriate period when necessary as part of a SEFA reconciliation process. Effect: Without proper reconciliation procedures, there is an increased risk that the SEFA may be materially misstated. The current year SEFA contained net adjustments of $209,443 made by the auditors to reconcile to the general ledger and award letters. Repeat Finding from Prior Year: Yes Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Views of Responsible Officials: The Comptroller will reconcile this report on a monthly basis making sure that all grants and other Federal / State expenditures are on the SEFA and that the two numbers reconcile with the general ledger. This will be kept in a notebook and the calendar kept in the Comptroller’s desk. The Comptroller will also create a folder in the business office folder on the server and input the current SEFA in this folder and show any discrepancies on a monthly basis and every time this report is run for drawdowns. This process will start immediately. The Comptroller will also make sure at year end that all items are on this report and they have been reconciled with the general ledger. This process will also be in the notebook and calendar within the desk of the Comptroller

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

2025-002 SEFA Presentation Error – Prior Year Program Name/Assistance Listing Number: 93.788 Opioid STR Federal Agency: Department of Health and Human Services Type of Finding: Significant Deficiency Compliance Requirement: Reporting Criteria: Uniform Guidance (2 CFR §200.510(b)) requires that the Schedule of Expenditures of Federal Awards (SEFA) accurately present all federal awards, including the correct identifying numbers assigned by pass-through entities for each award. Accurate reporting is essential to ensure compliance with funding requirements and enable proper tracking and monitoring of federal awards. Condition: During the current year audit, it was noted that the prior year’s SEFA contained an underreporting of $206,206.41 related to Grant ID 2401119 – Think Act and Live 2.0. While the total expenditures under the correct Assistance Listing Number (ALN) were accurate, the amounts assigned to this specific Grant ID were misclassified or omitted. Cause of Condition: The error occurred due to insufficient review procedures over SEFA preparation, specifically related to the accuracy of pass-through identifying numbers and grant-level allocations. Potential Effect of Condition: Although the error did not impact major program determination or the prior year audit opinion, it led to an incomplete and inaccurate SEFA presentation, which could affect tracking and monitoring of specific awards. Questioned Cost: Not applicable – the expenditures were allowable but misclassified. Recommendation: We recommend that management strengthen SEFA preparation and review controls by the following: a. Performing a detailed verification of grant-specific information, including Grant IDs, pass through numbers, and related allocations. b. Implementing a formal review process to ensure accuracy and completeness of the SEFA prior to submission. Description of the Nature and Extent of Issues Reported: During the current year audit, all misclassified expenditures related to Grant ID 2401119 – Think Act and Live 2.0 in the prior year SEFA were identified. The total underreported amount is $206,206.41, which exceeds both the program-level materiality threshold of $91,000 (based on a 5% benchmark of total awards expended for the major program 93.788) and the $25,000 SEFA reporting threshold under 2 CFR §200.516(a)(3). Management Response: Management concurred with the finding. The Organization has implemented the necessary internal controls to ensure that the grant reporting accurately reflects the expenditures for each of the respective grants.

Assistance Listing Number, Federal Agency, and Program Name ALN 14.251, U.S. Department of Housing and Urban Development, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Federal Award Identification Number and Year B 23 CP CO 0287 (2024) and B 23 CP WY 1616 (2024) Pass through Entity None Finding Type Material weakness Repeat Finding No Criteria The Organization should report its federal expenditures in the schedule in accordance with Uniform Guidance 2 CFR 200.510(b). Condition The 2025 schedule was initially overstated to include federal awards relating to ALN 14.251, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, expended during the year ended June 30, 2024. Questioned Costs None If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported N/A Identification of How Questioned Costs Were Computed N/A Context During audit testing over ALN 14.251, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, auditors identified $666,783 of expenditures related to fiscal year 2024 that were improperly included in the fiscal year 2025 schedule. The Organization subsequently amended the fiscal year 2025 schedule to exclude the fiscal year 2024 expenditures. Cause and Effect The Organization did not identify certain expenditures relating to fiscal year 2024 that were improperly included on the schedule during fiscal year 2025. The initial schedule provided to the auditors was overstated by $666,783, which impacted the initial major program determination. Recommendation We recommend the Organization evaluate its accounting policies to ensure federal awards are properly recognized in the schedule in the year of expenditure in accordance with Uniform Guidance 2 CFR 200.510(b). Views of Responsible Officials and Corrective Action Plan Food Bank of the Rockies, Inc. received a reimbursement grant for vehicles from the Department of Housing and Urban Development (HUD). While we purchased the vehicles in fiscal year 2024, we could not file the claim for reimbursement until fiscal year 2025. Guidance on the HUD claims process was greatly delayed for multiple reasons. We posted the cost and asset when ordered, following accounting principles generally accepted in the United States (GAAP). However, we did not include the funding on the 2024 schedule, as we had not yet filed the reimbursement claims, nor been given assurance they would be paid. Instead, we included it in the fiscal year 2025 schedule, as that was when the claims were filed and we had confirmation they would be paid in full. We understand now that, per Uniform Guidance 2 CFR 200.51(b), those funds should have been shown in the fiscal year 2024 schedule. With this understanding, moving forward we will include in the schedule amounts that have been spent for which we have an agreement for reimbursement, regardless of timing of the claim being filed or level of certainty of reimbursement.

Assistance Listing Number, Federal Agency, and Program Name - N/A, Schedule of Expenditures of Federal Awards (SEFA) Reporting Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Uniform Guidance (2 CFR 200.510(b)) requires a schedule of expenditures of federal awards (SEFA) that must provide total federal awards expended for the period covered by the auditee's financial statements. Federal awards expended in accordance with §200.502 should be based on when the underlying activity related to the federal award occurs. Condition - During our review of the schedule of expenditures of federal awards, we noted that certain federal program expenditures were included in the SEFA for the fiscal year ended June 30, 2025 even though the underlying activity occurred in 2024. The College did not have adequate controls in place to ensure the SEFA was prepared to include appropriate expenditures for the Economic Development Cluster in the proper period. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - During our review of the College's SEFA, we noted expenditures of $318,814 that were improperly included within the Economic Development Cluster in 2025. Based on review of underlying expenditures on vendor pay applications, expenditures should have been included on the SEFA in 2024. Cause and Effect - The College did not have adequate processes and internal control structure in place to ensure SEFA expenditures were recorded in the appropriate period. As a result, the SEFA is overstated by $318,814 in 2025. If the SEFA does not accurately reflect federal expenditures for the audit period, this could lead to misinterpretation of compliance requirements and inaccurate reporting to federal agencies. Recommendation - We recommend management implement procedures to ensure the SEFA preparation is based on the timing of the underlying activity rather than payment dates. Views of Responsible Officials and Planned Corrective Actions - The College will establish the proper controls to ensure that the SEFA is prepared based on the timing of the underlying activity rather than payment dates.

The City is required to have internal controls in place that enable it to prepare complete financial statements, including the schedule of expenditure of federal awards in accordance with generally accepted accounting standards and in accordance with the Uniform Guidance at 2 CFR 200.510(b).

Assistance Listing Number, Federal Agency, and Program Name - ALN 66.202, U.S. Environmental Protection Agency - Congressionally Mandated Projects Federal Award Identification Number and Year - CG-00E03697-0, 2024 Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 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. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass through entities to make the schedule easier to use. Condition - Controls were not in place to ensure that the schedule of expenditures of federal awards (SEFA) was 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 - N/A Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2025, the Village expended approximately $935,000 of federal funding from various federal agencies. The Village accumulates the financial data and other required information to complete the SEFA. Expenditures under grant ALN 66.202, Congressionally Mandated Projects, were originally overstated by $40,088 due to duplication of costs. No controls were in place to identify incompleteness or inaccuracy of the SEFA. Cause and Effect - No review or other control was in place to ensure the SEFA was complete and accurate. As a result, ALN 66.202, Congressionally Mandated Projects, expenditures were overstated by $40,088. This error has been corrected on the SEFA as of June 30, 2025. Recommendation - The Village should implement controls to ensure the SEFA is reviewed for completeness and accuracy. Views of Responsible Officials and Planned Corrective Actions - The Village has hired an outside contractor to assist with review of audit documents.

Management acknowledged its responsibility to establish and maintain effective internal controls to reasonably assure compliance with federal statutes, regulations and terms and conditions of federal awards and controls relating to preparing the Schedule of Expenditures of Federal Awards (the Schedule), as required by Uniform Guidance (2 CFR § 200.303(a)), in the audit engagement letter. Furthermore, Uniform Guidance (2 CFR Subpart F § 200.510(b)) requires the auditee prepare the Schedule for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. Due to insufficient controls over the monitoring of grant activity, the District did not retain appropriate support on the dates of the determination to charge prior year costs to the American Rescue Plan Elementary and Secondary School Emergency Relief Fund (ARP ESSER) grant in the amount of $678,544. The grant award was for $1,019,060, which had a grant period spanning calendar years 2020 through 2024. Lack of maintaining such documentation could result in expenditures determined to be unallowable under grant guidelines and funds required to be returned. Ineffective internal controls related to federal grants could lead to noncompliance with program requirements. Additionally, the determination of unallowable costs could have an adverse effect on future grant awards by the awarding agency or agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit. District management should implement a system to review the Schedule for errors and omissions as well as a method to monitor the related internal controls over compliance with federal grant requirements. This will help ensure the Schedule is complete and accurate, major federal programs are accurately identified for audit, and internal controls over compliance requirements are implemented and operating effectively.

Finding 2025-003 – Misreporting of Pass-Through Grant Expenditures in SLFRF Compliance Report Criteria: Per Uniform Guidance (2 CFR 200.331 and 2 CFR 200.510), pass-through entities must clearly identify federal awards to subrecipients, including the source of funding, applicable federal requirements, and the Assistance Listing number (21.027 for SLFRF). Subrecipients are required to report only those federal expenditures they directly administer on their Schedule of Expenditures of Federal Awards (SEFA), and not those administered by the pass-through entity. Expenditures of federal pass-through funds should be reported by the pass-through entity (e.g., OWRB) and not by the subrecipient (the City of Sand Springs). Condition: During review of the ARPA Funds Project Spending for March 2025, it was identified that the City of Sand Springs reported $2,392,701.84 in current period expenditures for project #479952 in the SLFRF Compliance report. However, only $1,109,205.41 should have been reported. The discrepancy resulted from the mistaken inclusion of expenditures from the OWRB Grant (a federal pass-through grant from ARPA) in the City of Sand Springs's SLFRF report. Cause and Effect: The Finance Director was unaware that the City of Sand Springs was utilizing OWRB funds (ARPA pass-through) first, followed by direct ARPA funds. As a result, expenditures from the OWRB Grant were incorrectly included in the City of Sand Springs's SLFRF Compliance report, rather than being reported by OWRB as the pass-through entity. The City of Sand Springs's SLFRF Compliance report overstated federal expenditures by $1,283,496.43 for the period. This misreporting could result in inaccurate federal reporting, potential questioned costs, and noncompliance with Uniform Guidance and SLFRF requirements. It also constitutes a significant deficiency in internal controls over federal award reporting. Recommendation: We recommend that the City of Sand Springs implement procedures to ensure that only expenditures of direct federal awards are reported in the SLFRF Compliance report. Expenditures from federal pass-through grants should be tracked separately and reported by the appropriate pass-through entity. Staff responsible for federal reporting should receive training on the distinction between direct and pass-through federal funds and related reporting requirements. Management Response: Management concurs with the finding. The Finance Department will update its procedures to ensure that only direct ARPA funds are reported in the SLFRF Compliance report. Expenditures from OWRB pass-through grants will be tracked separately and excluded from the City of Sand Springs's SLFRF reporting. Staff will receive additional training on federal grant reporting requirements. The City of Sand Springs will coordinate with OWRB to ensure proper reporting of pass-through funds.

Federal Agency: Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Wood County ADAMH Board Award Period: May 8, 2024 – September 29, 2026 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: Uniform Guidance (2 CFR Part 200.510) provides requirements over procurement and suspension & debarment for grantees when entering into contracts funded by federal programs. Questioned Costs: None Condition: No suspension and debarment exclusion check was performed for one of the two contractors paid with funds under the federal program. Cause: No formal procurement and suspension and debarment policies were in place for the year under audit. Context: Of the two contracts entered into for the program, suspension and debarment checks were not performed for one of the two contractors. Effect: Federal funds could have been paid to a federally suspended and debarred entity. Per review of the federal suspension and debarred list, both entities contracted with under the grant are not suspended or debarred. Repeat Finding: No Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Guidance. Procurement policy should include general procurement standards as described by the Uniform Guidance, that include standards on conduct covering conflicts of interest; method of procurement for micro-purchases, small purchases, sealed bids, and proposals; and all other criteria as outlined in 2CFR 200.318 through 200.327. Views of Responsible Officials and Planned Corrective Actions: Management will develop and implement a procurement policy that is in compliance with the Uniform Guidance.

2025-003 (2023-002) – INACCURATE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: All (see Schedule of Expenditures of Federal Awards) Title: All (see Schedule of Expenditures of Federal Awards) AL #: All (see Schedule of Expenditures of Federal Awards) Award #: All (see Schedule of Expenditures of Federal Awards) Award Period: All (see Schedule of Expenditures of Federal Awards) Questioned Costs: None Statement of Condition The Schedule of Expenditures of Federal Awards (SEFA) was provided timely to the auditors; however, several adjustments were identified during the audit process: • The SEFA incorrectly included match expenditures, requiring an reduction to the federal expenses of $324,936. Without accurate recording of federal award expenditures, auditors cannot appropriately assess and select federal programs for testing as mandated by the Single Audit Act. Management’s Progress Toward Prior Year Corrective Action Plan: The County has made progress toward addressing the prior year’s SEFA accuracy finding; however, additional corrections remain necessary, as noted above. Criteria 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 requirements. Good internal control practices require the entity to have documented procedures for: • Properly identifying federal, state, and other funding sources. • Classifying expenditures accurately under the correct federal assistance listing numbers. • Ensuring expenditures reported on the SEFA are accurate and presented according to requirements. Additionally, 2 CFR 200.510(b) mandates the preparation of an accurate and complete SEFA for the audit period, including federal expenditures as determined in accordance with 2 CFR 200.502. Cause The County did not have comprehensive controls to ensure that all federal expenditures are correctly tracked, accurately classified, and properly reported on the SEFA. Effect Without accurate, timely tracking and reporting of federal expenditures, the County is at risk of improperly accounting for federal awards, potentially leading to noncompliance, questioned costs, or repayment obligations. Recommendation We recommend that the County establish, document, and implement a comprehensive internal control structure specifically designed to: • Clearly identify, track, and report grant expenditures. • Accurately distinguish between federal and non-federal expenditures. • Prepare and review the SEFA regularly to ensure completeness, accuracy, and compliance with the Uniform Guidance (2 CFR 200.502 and .510) accrual-basis requirements.