CITY OF CORTLANDLocal Government

Federal Award Findings and Questioned Costs Finding 2023-007 Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury; U.S. Department of Housing and Urban Development Federal Program: Coronavirus State and Local Fiscal Recovery Funds; Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 21.027; 14.228 Pass-Through Agency: NYS Office of the State Comptroller; NYS Office of Community Renewal Criteria:Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2023. Cause:Staffing shortages caused the delays in financial reporting. Effect or Potential Effect: As a result, the entity is not incompliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Context:This year's Single Audit reporting package was filed in early April, approximately six months after the required filing date. This compares with the prior year, when the Single Audit reporting package was filed September 26, 2023, which was prior to the required filing date. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City is still facing staffing shortages and is working to get the subsequent financial statements completed. It is expected the 2024 reporting package will be filed on time.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury; U.S. Department of Housing and Urban Development Federal Program: Coronavirus State and Local Fiscal Recovery Funds; Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 21.027; 14.228 Pass-Through Agency: NYS Office of the State Comptroller; NYS Office of Community Renewal Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2023. Cause: Staffing shortages caused the delays in financial reporting. Effect or Potential Effect: As a result, the entity is not incompliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Context: This year's Single Audit reissued reporting package was filed in mid August, after the required filing date. This compares with the prior year, when the initial Single Audit reporting package was filed timely, but the reissued reporting package was filed after the required filing date. Repeat Finding: This finding is a repeat of finding 2022-008 from the prior year. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City is still facing staffing shortages and is working to get the subsequent financial statements completed. It is expected the 2024 reporting package will be filed on time.

Federal Award Findings and Questioned Costs - Continued Finding 2023-008 Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee’s financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor’s identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: 1. ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 20.600 / 20.616 Highway Safety Cluster 2. ALN 66.818 Brownfield Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.039 (COVID-19) Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause:The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it receives. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs:None. Context:The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $253,510. Repeat Finding:This finding is not a repeat finding. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee:The City agrees with the finding.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee’s financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor’s identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: 1. ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 20.600 / 20.616 Highway Safety Cluster 2. ALN 66.818 Brownfield Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.039 (COVID-19) Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it receives. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $253,510. Repeat Finding: This finding is a repeat of finding 2022-006 and 2022-007 from the prior year. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding.

Federal Award Findings and Questioned Costs Finding 2023-007 Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury; U.S. Department of Housing and Urban Development Federal Program: Coronavirus State and Local Fiscal Recovery Funds; Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 21.027; 14.228 Pass-Through Agency: NYS Office of the State Comptroller; NYS Office of Community Renewal Criteria:Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2023. Cause:Staffing shortages caused the delays in financial reporting. Effect or Potential Effect: As a result, the entity is not incompliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Context:This year's Single Audit reporting package was filed in early April, approximately six months after the required filing date. This compares with the prior year, when the Single Audit reporting package was filed September 26, 2023, which was prior to the required filing date. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City is still facing staffing shortages and is working to get the subsequent financial statements completed. It is expected the 2024 reporting package will be filed on time.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury; U.S. Department of Housing and Urban Development Federal Program: Coronavirus State and Local Fiscal Recovery Funds; Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 21.027; 14.228 Pass-Through Agency: NYS Office of the State Comptroller; NYS Office of Community Renewal Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2023. Cause: Staffing shortages caused the delays in financial reporting. Effect or Potential Effect: As a result, the entity is not incompliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Context: This year's Single Audit reissued reporting package was filed in mid August, after the required filing date. This compares with the prior year, when the initial Single Audit reporting package was filed timely, but the reissued reporting package was filed after the required filing date. Repeat Finding: This finding is a repeat of finding 2022-008 from the prior year. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City is still facing staffing shortages and is working to get the subsequent financial statements completed. It is expected the 2024 reporting package will be filed on time.

Federal Award Findings and Questioned Costs - Continued Finding 2023-008 Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee’s financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor’s identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: 1. ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 20.600 / 20.616 Highway Safety Cluster 2. ALN 66.818 Brownfield Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.039 (COVID-19) Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause:The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it receives. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs:None. Context:The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $253,510. Repeat Finding:This finding is not a repeat finding. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee:The City agrees with the finding.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee’s financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor’s identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: 1. ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 20.600 / 20.616 Highway Safety Cluster 2. ALN 66.818 Brownfield Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.039 (COVID-19) Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it receives. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $253,510. Repeat Finding: This finding is a repeat of finding 2022-006 and 2022-007 from the prior year. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding.

Finding 2022-004 Issue: Noncompliance with Reporting Requirements Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: NYS Office of the State Comptroller Criteria: Under the requirements of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program as codified in 31 CFR Part 35 Subpart A, recipients are required to provide periodic reports providing detailed accounting of the use of funds, modifications to a State or Territory's tax revenue sources, and such other information as may be required (31 CFR 35.4[c]). Under this same requirement, non-entitlement units of local government were required to submit a Project and Expenditure Report (the Report) by April 30, 2022 and then annually thereafter. Condition: The City did not file the Report due by April 30, 2022. Cause: The City did not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: The City is not in compliance with the federal regulations regarding reporting. Questioned Costs: None. Context: The City was aware of the reporting requirement prior to the single audit; however, they were not able to accurately and appropriately certify the report. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the City ensure all required reports are filed in a timely manner. In addition, we recommend the City completes and files the required Report as soon as practicable. Views of Responsible Officials of the Auditee: The City agrees with the finding and has already implemented a detailed tracking guide and is prepared to meet future reporting requirements for this funding.

Issue: Noncompliance with Reporting Requirements Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: NYS Office of the State Comptroller Criteria: Under the requirements of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program as codified in 31 CFR Part 35 Subpart A, recipients are required to provide periodic reports providing detailed accounting of the use of funds, modifications to a State or Territory's tax revenue sources, and such other information as may be required (31 CFR 35.4[c]). Under this same requirement, non-entitlement units of local government were required to submit a Project and Expenditure Report (the Report) by April 30, 2022 and then annually thereafter. Condition: The City did not file the Report due by April 30, 2022. Cause: The City did not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: The City is not in compliance with the federal regulations regarding reporting. Questioned Costs: None. Context: The City was aware of the reporting requirement prior to the single audit; however, they were not able to accurately and appropriately certify the report. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the City ensure all required reports are filed in a timely manner. In addition, we recommend the City completes and files the required Report as soon as practicable. Views of Responsible Officials of the Auditee: The City agrees with the finding and has already implemented a detailed tracking guide and is prepared to meet future reporting requirements for this funding.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Environmental Protection Agency Federal Program: Capitalization Grants for Clean Water State Revolving Fund Assistance Listing Number: 66.458 Pass-Through Agency: NYS Environmental Facilities Corporation Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee's financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor's identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 16.554 National Criminal History Improvement Program (NCHIP) 2. ALN 20.600 State and Community Highway Safety 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.044 Assistance to Firefighters Grant 6. ALN 97.067 Homeland Security Grant Program Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it received. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $892,160. Repeat Finding: This finding is a repeat of finding 2021-007 from the prior year. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding and will develop a method for accurately tracking federal expenditures.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Housing and Urban Development, U.S. Department of the Treasury, Environmental Protection Agency Federal Program: Community Development Block Grants/States Program, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 14.228, 21.027, 66.458 Pass-Through Agency: NYS Office of Community Renewal, NYS Environmental Facilities Corporation Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Cause/Condition: Staffing shortages caused the delays in financial reporting. This deadline was not met on a timely basis for the year ended December 31, 2022. Effect or Potential Effect: As a result, the entity is not in compliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Repeat Finding: This finding is a repeat of finding 2021-004 from the prior year. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City agrees with the finding and expects the 2024 reporting package will be filed on time

Issue: Noncompliance with Procurement Suspension and Debarment Requirements Classification: Significant Deficiency Federal Agency: Environmental Protection Agency Federal Program: Capitalization Grants for Clean Water State Revolving Fund Assistance Listing Number: 66.458 Pass-Through Agency: NYS Environmental Facilities Corporation Criteria: Under the requirements of the Capitalization Grants for Clean Water State Revolving Funds the City is required to verify that an entity with which it plans to contract is not debarred, suspended, or otherwise excluded. Condition: The City did not document that it verified that entities with which it plans to contract with are not debarred, suspended, or otherwise excluded. Cause: The City was aware of the requirements regarding suspension and debarment but was not aware of the requirement to document verification. Effect or Potential Effect: The City is not in compliance with procurement requirements. Questioned Costs: None. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that the City document its verification that contractors are not debarred, suspended, or otherwise excluded. Views of Responsible Officials of the Auditee: The City agrees with the finding.

Finding 2022-004 Issue: Noncompliance with Reporting Requirements Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: NYS Office of the State Comptroller Criteria: Under the requirements of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program as codified in 31 CFR Part 35 Subpart A, recipients are required to provide periodic reports providing detailed accounting of the use of funds, modifications to a State or Territory's tax revenue sources, and such other information as may be required (31 CFR 35.4[c]). Under this same requirement, non-entitlement units of local government were required to submit a Project and Expenditure Report (the Report) by April 30, 2022 and then annually thereafter. Condition: The City did not file the Report due by April 30, 2022. Cause: The City did not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: The City is not in compliance with the federal regulations regarding reporting. Questioned Costs: None. Context: The City was aware of the reporting requirement prior to the single audit; however, they were not able to accurately and appropriately certify the report. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the City ensure all required reports are filed in a timely manner. In addition, we recommend the City completes and files the required Report as soon as practicable. Views of Responsible Officials of the Auditee: The City agrees with the finding and has already implemented a detailed tracking guide and is prepared to meet future reporting requirements for this funding.

Issue: Noncompliance with Reporting Requirements Classification: Material Noncompliance Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: NYS Office of the State Comptroller Criteria: Under the requirements of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program as codified in 31 CFR Part 35 Subpart A, recipients are required to provide periodic reports providing detailed accounting of the use of funds, modifications to a State or Territory's tax revenue sources, and such other information as may be required (31 CFR 35.4[c]). Under this same requirement, non-entitlement units of local government were required to submit a Project and Expenditure Report (the Report) by April 30, 2022 and then annually thereafter. Condition: The City did not file the Report due by April 30, 2022. Cause: The City did not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: The City is not in compliance with the federal regulations regarding reporting. Questioned Costs: None. Context: The City was aware of the reporting requirement prior to the single audit; however, they were not able to accurately and appropriately certify the report. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the City ensure all required reports are filed in a timely manner. In addition, we recommend the City completes and files the required Report as soon as practicable. Views of Responsible Officials of the Auditee: The City agrees with the finding and has already implemented a detailed tracking guide and is prepared to meet future reporting requirements for this funding.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Environmental Protection Agency Federal Program: Capitalization Grants for Clean Water State Revolving Fund Assistance Listing Number: 66.458 Pass-Through Agency: NYS Environmental Facilities Corporation Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee's financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor's identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were not identified on the initial SEFA for the year under audit: 1. ALN 16.554 National Criminal History Improvement Program (NCHIP) 2. ALN 20.600 State and Community Highway Safety 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.044 Assistance to Firefighters Grant 6. ALN 97.067 Homeland Security Grant Program Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it received. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $892,160. Repeat Finding: This finding is a repeat of finding 2021-007 from the prior year. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding and will develop a method for accurately tracking federal expenditures.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Classification: Material Noncompliance Federal Agency: U.S. Department of Housing and Urban Development, U.S. Department of the Treasury, Environmental Protection Agency Federal Program: Community Development Block Grants/States Program, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 14.228, 21.027, 66.458 Pass-Through Agency: NYS Office of Community Renewal, NYS Environmental Facilities Corporation Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Cause/Condition: Staffing shortages caused the delays in financial reporting. This deadline was not met on a timely basis for the year ended December 31, 2022. Effect or Potential Effect: As a result, the entity is not in compliance with §200.512 of the Uniform Guidance. Questioned Costs: None. Repeat Finding: This finding is a repeat of finding 2021-004 from the prior year. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City agrees with the finding and expects the 2024 reporting package will be filed on time

Issue: Noncompliance with Procurement Suspension and Debarment Requirements Classification: Significant Deficiency Federal Agency: Environmental Protection Agency Federal Program: Capitalization Grants for Clean Water State Revolving Fund Assistance Listing Number: 66.458 Pass-Through Agency: NYS Environmental Facilities Corporation Criteria: Under the requirements of the Capitalization Grants for Clean Water State Revolving Funds the City is required to verify that an entity with which it plans to contract is not debarred, suspended, or otherwise excluded. Condition: The City did not document that it verified that entities with which it plans to contract with are not debarred, suspended, or otherwise excluded. Cause: The City was aware of the requirements regarding suspension and debarment but was not aware of the requirement to document verification. Effect or Potential Effect: The City is not in compliance with procurement requirements. Questioned Costs: None. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend that the City document its verification that contractors are not debarred, suspended, or otherwise excluded. Views of Responsible Officials of the Auditee: The City agrees with the finding.

Finding 2021-004 Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Federal Agency: Not applicable. Federal Program: Not applicable. Assistance Listing Number: Not applicable. Pass-Through Agency: Not applicable. Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), ?200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2021. Cause: The City experienced significant turnover within key positions of the Finance and Administration departments, which has caused delays in financial reporting. Effect or Potential Effect: The entity is not incompliance with ?200.512 of the Uniform Guidance. Questioned Costs: None. Context: This year's Single Audit reporting package was filed on September 27, 2023, approximately 12 months after the required filing date. This compares with the prior year, when the Single audit reporting package was filed on November 22, 2021, approximately 2 months after the required filing date. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the requirements of ?200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies and learn prior practices and financial systems in order to prepare timely information for the auditor. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, ?200.512.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Federal Agency: Not applicable. Federal Program: Not applicable. Assistance Listing Number: Not applicable. Pass-Through Agency: Not applicable. Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2021. Cause: The City experienced significant turnover within key positions of the Finance and Administration departments, which has caused delays in financial reporting. Effect or Potential Effect: The entity is not in compliance with §200.512 of the Uniform Guidance. Questioned Costs: None Context: This year's Single Audit reporting package was filed on September 27, 2023, approximately 12 months after the required filing date. This compares with the prior year, when the Single audit reporting package was filed on November 22, 2021, approximately 2 months after the required filing date. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies and learn prior practices and financial systems in order to prepare timely information for the auditor. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, §200.512.

Issue: Lack of Controls Surrounding Oversight of Federal Expenditures Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/States Program Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: Internal controls over financial reporting should be properly designed, implemented, and monitored to ensure all material transactions are recorded properly. Condition: No controls could be derived related to funding that was expneded by another organization after being passed through the City. Cause: The City experienced significant turnover within key positions of the Finance and Administration department, which caused controls for oversight of funds distributed to be overlooked, including proper recording and retention of supporting documentation. Effect or Potential Effect: Adjustments were recorded in several funds, as discussed below under "Context", as a result of audit procedures. Questioned Costs: None. Context: Audit adjustments, as summarized below, were recorded in the noted funds as a result of our audit procedures. These audit adjustments have also been communicated separately in our required communications letter. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City implement processes to monitor and reconcile account balances and record transactions in the proper period. Adjustments that are necessary should be recorded and supporting documentation should be retained when available. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, §200.512.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/States Program Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee's financial statement. It is the responibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor's identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified, or had inaccurate amounts reported, on the initial SEFA for the year under audit: ALN 10.664 Cooperative Forestry Assistance - not identified ALN 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) - inaccurate amounts reported ALN 21.027 (COVID-19) Coronavirus State and Local Fiscal Recovery Funds - inaccurate amounts reported Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it received. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $366,330. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding.

Finding 2021-004 Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Federal Agency: Not applicable. Federal Program: Not applicable. Assistance Listing Number: Not applicable. Pass-Through Agency: Not applicable. Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), ?200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2021. Cause: The City experienced significant turnover within key positions of the Finance and Administration departments, which has caused delays in financial reporting. Effect or Potential Effect: The entity is not incompliance with ?200.512 of the Uniform Guidance. Questioned Costs: None. Context: This year's Single Audit reporting package was filed on September 27, 2023, approximately 12 months after the required filing date. This compares with the prior year, when the Single audit reporting package was filed on November 22, 2021, approximately 2 months after the required filing date. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the requirements of ?200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies and learn prior practices and financial systems in order to prepare timely information for the auditor. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, ?200.512.

Issue: Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Federal Agency: Not applicable. Federal Program: Not applicable. Assistance Listing Number: Not applicable. Pass-Through Agency: Not applicable. Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Condition: This deadline was not met on a timely basis for the year ended December 31, 2021. Cause: The City experienced significant turnover within key positions of the Finance and Administration departments, which has caused delays in financial reporting. Effect or Potential Effect: The entity is not in compliance with §200.512 of the Uniform Guidance. Questioned Costs: None Context: This year's Single Audit reporting package was filed on September 27, 2023, approximately 12 months after the required filing date. This compares with the prior year, when the Single audit reporting package was filed on November 22, 2021, approximately 2 months after the required filing date. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies and learn prior practices and financial systems in order to prepare timely information for the auditor. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, §200.512.

Issue: Lack of Controls Surrounding Oversight of Federal Expenditures Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/States Program Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: Internal controls over financial reporting should be properly designed, implemented, and monitored to ensure all material transactions are recorded properly. Condition: No controls could be derived related to funding that was expneded by another organization after being passed through the City. Cause: The City experienced significant turnover within key positions of the Finance and Administration department, which caused controls for oversight of funds distributed to be overlooked, including proper recording and retention of supporting documentation. Effect or Potential Effect: Adjustments were recorded in several funds, as discussed below under "Context", as a result of audit procedures. Questioned Costs: None. Context: Audit adjustments, as summarized below, were recorded in the noted funds as a result of our audit procedures. These audit adjustments have also been communicated separately in our required communications letter. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City implement processes to monitor and reconcile account balances and record transactions in the proper period. Adjustments that are necessary should be recorded and supporting documentation should be retained when available. Views of Responsible Officials of the Auditee: The City experienced substantial turnover in 2021 including the departure of both the Finance Director and Deputy Director, followed by additional retirements over the next fiscal year. With the multiple vacancies and limited succession planning, it made it challenging for new staff to meet the demands of current operations with vacancies. Prior practices relied heavily on institutional knowledge, year-end adjustments and audit journal entries to identify federal grant expenditures. In addition, there remains a lack of centralized grant and contract awards which contributed to the lack of detailed tracking of information and timely reporting of information requested by the auditor, in order to complete financial statements for submission deadlines outlined in Uniform Guidance, §200.512.

Issue: Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) Classification: Material Weakness Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Community Development Block Grants/States Program Assistance Listing Number: 14.228 Pass-Through Agency: NYS Office of Community Renewal Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee's financial statement. It is the responibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor's identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were materially misstated; including the following major federal program for the year under audit: ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified, or had inaccurate amounts reported, on the initial SEFA for the year under audit: ALN 10.664 Cooperative Forestry Assistance - not identified ALN 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) - inaccurate amounts reported ALN 21.027 (COVID-19) Coronavirus State and Local Fiscal Recovery Funds - inaccurate amounts reported Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it received. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None. Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $366,330. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Views of Responsible Officials of the Auditee: The City agrees with the finding.