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The SEED Public Charter School of Washington, D.C.Non-Profit

EIN: 420714325

UEI: FYD3L7RCNLL3

Audited by: RSM US LLP

Oversight agency: 84 [Department of Education]

View federal awards & risk assessment →

Data as of September 2, 2026

The SEED Public Charter School of Washington, D.C.8 audit years9 findings3 repeat
8
Audit Years
9
Total Findings
3
Repeat Findings
$1.3M
Federal Awards Expended (FY 2025)

FY 2025-06-30

LOW-RISK AUDITEE$1,277,287 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 23, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 23, 2026 (73 days ago).

What is a management decision? →
2025-006
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-005

The single audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Questioned costs: None noted. Context: The federal single audit for the current fiscal year was issued significantly earlier than in the prior fiscal year, however it was still submitted after the deadline. Cause: The City and Board of Education are not audit-ready in a timely manner. Effect: This can result in errors reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Repeat Finding: Yes (2024-005) Recommendation: We recommend the City and Board of Education develop a more robust audit readiness schedule. Ultimately a comprehensive accounting policies and procedures manual should also be developed. Lastly, the City should consider allocating additional resources/personnel to the City Finance Office to assist with the audit. Views of responsible officials: Management agrees with this finding.

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Full finding narrative

Late Single Audit Submission Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the schedules of expenditures of federal awards for fiscal years 2022-2025. Type of Finding: Significant Deficiency in Internal Control over Compliance – Other Matter Criteria or specific requirement: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: The single audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Questioned costs: None noted. Context: The federal single audit for the current fiscal year was issued significantly earlier than in the prior fiscal year, however it was still submitted after the deadline. Cause: The City and Board of Education are not audit-ready in a timely manner. Effect: This can result in errors reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Repeat Finding: Yes (2024-005) Recommendation: We recommend the City and Board of Education develop a more robust audit readiness schedule. Ultimately a comprehensive accounting policies and procedures manual should also be developed. Lastly, the City should consider allocating additional resources/personnel to the City Finance Office to assist with the audit. Views of responsible officials: Management agrees with this finding.

Corrective Action Plan

Late Single Audit Submission Description of Finding Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action Management will review existing processes and controls related to audit readiness and financial reporting to ensure that all required financial reports are submitted timely. The City will implement a formal audit and Single Audit submission calendar with defined internal deadlines, assign clear staff responsibilities for preparing and submitting required documents, and use a centralized tracker to monitor audit milestones and ensure timely submission to the Federal Audit Clearinghouse. Staff involved in federal reporting will also receive annual training on Single Audit requirements to ensure compliance with federal timelines going forward. Name of Contact Person Shannon McCue, City Budget Director Projected Completion Date June 30, 2026

Prior Finding References

2024-005

About Reporting →
2025-007
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Questioned costs: None noted. Context: There was no documentation available to show that the proper verification occurred prior to entering into the purchase order or formal agreement for 6 out of 6 selections tested. However, none of the vendors selected for testing were suspended or debarred. Cause: Out of a statistically valid sample of 6 vendors, Board of Education Finance Office / City Purchasing Department could not provide documentation to prove verification that vendors were not suspended or debarred occurred prior to executing the purchase order or formal agreement for all 6 vendors selected. Effect: If procedures to verify that vendors are not suspended or debarred do not occur, the City is at risk for noncompliance as it relates to federal program requirements. Repeat Finding: No Recommendation: We recommend that the Board of Education Finance Office and City Purchasing Department review their suspension and debarment verification processes and related controls to ensure that the verification is occurring, and documentation is properly maintained. Views of responsible officials: Management agrees with this finding.

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Full finding narrative

Suspension and Debarment Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 / 84.173 Federal Award Identification Number and Year: HO27A230021 - 2023 (84.027) HO27A240021 - 2024 (84.027) H173A230024 - 2023 (84.173) H173A240024 - 2024 (84.173) Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20977-2024 12060-SDE64370-20983-2024 12060-SDE64370-20977-2025 12060-SDE64370-20983-2025 Award Period: 7/1/2023-6/30/2025 (2024 Grant) 7/1/2024-6/30/2026 (2025 Grant) Type of Finding: Material Weakness – Other Matter Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Questioned costs: None noted. Context: There was no documentation available to show that the proper verification occurred prior to entering into the purchase order or formal agreement for 6 out of 6 selections tested. However, none of the vendors selected for testing were suspended or debarred. Cause: Out of a statistically valid sample of 6 vendors, Board of Education Finance Office / City Purchasing Department could not provide documentation to prove verification that vendors were not suspended or debarred occurred prior to executing the purchase order or formal agreement for all 6 vendors selected. Effect: If procedures to verify that vendors are not suspended or debarred do not occur, the City is at risk for noncompliance as it relates to federal program requirements. Repeat Finding: No Recommendation: We recommend that the Board of Education Finance Office and City Purchasing Department review their suspension and debarment verification processes and related controls to ensure that the verification is occurring, and documentation is properly maintained. Views of responsible officials: Management agrees with this finding.

Corrective Action Plan

Suspension and Debarment Description of Finding 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education Finance Office, in conjunction with the City Purchasing Department, will review and enhance their processes and controls over the verification that vendors are not suspended or debarred. Name of Contact Person Amilcar Hernandez, Board of Education Chief Financial Officer Projected Completion Date June 30, 2026

About Procurement and Suspension and Debarment →

FY 2025-06-30

$129,907,982 federal awards expended

FAC accepted this audit on May 21, 2026 — management decision was due November 21, 2026.

2025-006
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-005

The single audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Questioned costs: None noted. Context: The federal single audit for the current fiscal year was issued significantly earlier than in the prior fiscal year, however it was still submitted after the deadline. Cause: The City and Board of Education are not audit-ready in a timely manner. Effect: This can result in errors reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Repeat Finding: Yes (2024-005) Recommendation: We recommend the City and Board of Education develop a more robust audit readiness schedule. Ultimately a comprehensive accounting policies and procedures manual should also be developed. Lastly, the City should consider allocating additional resources/personnel to the City Finance Office to assist with the audit. Views of responsible officials: Management agrees with this finding.

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Full finding narrative

Late Single Audit Submission Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the schedules of expenditures of federal awards for fiscal years 2022-2025. Type of Finding: Significant Deficiency in Internal Control over Compliance – Other Matter Criteria or specific requirement: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: The single audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Questioned costs: None noted. Context: The federal single audit for the current fiscal year was issued significantly earlier than in the prior fiscal year, however it was still submitted after the deadline. Cause: The City and Board of Education are not audit-ready in a timely manner. Effect: This can result in errors reported in the SEFA, SESFA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Repeat Finding: Yes (2024-005) Recommendation: We recommend the City and Board of Education develop a more robust audit readiness schedule. Ultimately a comprehensive accounting policies and procedures manual should also be developed. Lastly, the City should consider allocating additional resources/personnel to the City Finance Office to assist with the audit. Views of responsible officials: Management agrees with this finding.

Corrective Action Plan

Late Single Audit Submission Description of Finding Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action Management will review existing processes and controls related to audit readiness and financial reporting to ensure that all required financial reports are submitted timely. The City will implement a formal audit and Single Audit submission calendar with defined internal deadlines, assign clear staff responsibilities for preparing and submitting required documents, and use a centralized tracker to monitor audit milestones and ensure timely submission to the Federal Audit Clearinghouse. Staff involved in federal reporting will also receive annual training on Single Audit requirements to ensure compliance with federal timelines going forward. Name of Contact Person Shannon McCue, City Budget Director Projected Completion Date June 30, 2026

Prior Finding References

2024-005

About Reporting →
2025-007
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Questioned costs: None noted. Context: There was no documentation available to show that the proper verification occurred prior to entering into the purchase order or formal agreement for 6 out of 6 selections tested. However, none of the vendors selected for testing were suspended or debarred. Cause: Out of a statistically valid sample of 6 vendors, Board of Education Finance Office / City Purchasing Department could not provide documentation to prove verification that vendors were not suspended or debarred occurred prior to executing the purchase order or formal agreement for all 6 vendors selected. Effect: If procedures to verify that vendors are not suspended or debarred do not occur, the City is at risk for noncompliance as it relates to federal program requirements. Repeat Finding: No Recommendation: We recommend that the Board of Education Finance Office and City Purchasing Department review their suspension and debarment verification processes and related controls to ensure that the verification is occurring, and documentation is properly maintained. Views of responsible officials: Management agrees with this finding.

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Full finding narrative

Suspension and Debarment Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 / 84.173 Federal Award Identification Number and Year: HO27A230021 - 2023 (84.027) HO27A240021 - 2024 (84.027) H173A230024 - 2023 (84.173) H173A240024 - 2024 (84.173) Pass-Through Agency: Connecticut State Department of Education Pass-Through Number(s): 12060-SDE64370-20977-2024 12060-SDE64370-20983-2024 12060-SDE64370-20977-2025 12060-SDE64370-20983-2025 Award Period: 7/1/2023-6/30/2025 (2024 Grant) 7/1/2024-6/30/2026 (2025 Grant) Type of Finding: Material Weakness – Other Matter Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Questioned costs: None noted. Context: There was no documentation available to show that the proper verification occurred prior to entering into the purchase order or formal agreement for 6 out of 6 selections tested. However, none of the vendors selected for testing were suspended or debarred. Cause: Out of a statistically valid sample of 6 vendors, Board of Education Finance Office / City Purchasing Department could not provide documentation to prove verification that vendors were not suspended or debarred occurred prior to executing the purchase order or formal agreement for all 6 vendors selected. Effect: If procedures to verify that vendors are not suspended or debarred do not occur, the City is at risk for noncompliance as it relates to federal program requirements. Repeat Finding: No Recommendation: We recommend that the Board of Education Finance Office and City Purchasing Department review their suspension and debarment verification processes and related controls to ensure that the verification is occurring, and documentation is properly maintained. Views of responsible officials: Management agrees with this finding.

Corrective Action Plan

Suspension and Debarment Description of Finding 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. During our audit, we noted that the Board of Education Finance Office / City Purchasing Department did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action The Board of Education Finance Office, in conjunction with the City Purchasing Department, will review and enhance their processes and controls over the verification that vendors are not suspended or debarred. Name of Contact Person Amilcar Hernandez, Board of Education Chief Financial Officer Projected Completion Date June 30, 2026

About Procurement and Suspension and Debarment →

FY 2025-05-31

LOW-RISK AUDITEE$18,912,155 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 5, 2025 — management decision was due April 5, 2026.

FY 2024-09-30

LOW-RISK AUDITEE$18,771,915 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 27, 2024 — management decision was due June 27, 2025.

FY 2024-06-30

LOW-RISK AUDITEE$1,208,367 federal awards expended

FAC accepted this audit on December 17, 2024 — management decision was due June 17, 2025.

2024-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003OTHER MATTERS

Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

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Assistance Listing Program Title and Number: Lead Hazard Reduction Grant Program 14.900 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: N/A Award year: Various Criteria or specific requirement: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022 to June 30, 2023 by January 10, 2024. Condition: Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-002: Significant Deficiency and Noncompliance Finding, Reporting-Annual Program: Lead-Based Paint Hazard Reduction Grant Program Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022, to June 30, 2023, by January 10, 2024. Based on our testing of the required quarterly and annual reports we determined the annual report was not submitted as required. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy has been implemented with centralized tracking to monitor grant reporting deadlines and prevent missed submissions. 2. The Office of Management, Policy, and Grants is establishing a Grant Management Team to conduct a secondary review of all reporting-related entries and ensure timely submissions. These actions will be implemented by the end of the next fiscal year, with all policy updates and training completed by October 31, 2025. 3. Health Department: The Health Department and the City’s Internal Auditor are creating Standard Operation Procedures and will train staff by December 31, 2025. 4. Contacts: Shannon McCue, Director of Management, Policy, and Grants; Maritza Bond, Health Director, Anticipated Completion Date: January 2026

Prior Finding References

2023-003

About Reporting →
2024-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Coronavirus State and Local Fiscal Recovery Funds Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally funded projects, it does not maintain formal documentation that this procedure occurred. Corrective Actions Taken: 1. Develop Standard Documentation: Create a standardized verification form or checklist for suspension and debarment checks. Include fields for date, method of verification (e.g., SAM.gov search), name of reviewer, and signature. 2. Integrate into Procurement Workflow: Require completion and attachment of the verification form to all federally funded purchase orders and contracts before approval. Embed verification as a required step in MUNIS or other procurement software workflows, if possible. 3. Staff Training: Provide refresher training for purchasing and finance staff on federal compliance requirements, including suspension and debarment procedures. Emphasize the importance of documentation for audit and compliance purposes. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

About Procurement and Suspension and Debarment →
2024-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Without documented evidence verifying whether the City was following its policy, the City could not provide evidence of this control being completed for federally funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Corrective Actions Taken: 1. Establish Documentation Protocols: The City is implementing standard templates and procedures for verifying suspension and debarment status, including documentation requirements. 2. System Integration and Workflow Updates: These procedures will be integrated into procurement workflows and reviewed regularly to ensure consistency across all federally funded contracts. 3. Monitoring and Oversight: A designated staff member will perform periodic reviews to confirm verification procedures are being followed and properly documented. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-005
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-004OTHER MATTERS

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

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Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

Corrective Action Plan

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023, and June 30, 2022. Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed, and the data collection form and reporting package should be submitted within 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023, and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024, and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late. Corrective Actions Taken: 1. Improved Reporting Processes: The City has streamlined the audit reporting process through enhanced coordination with auditors and improvements to internal procedures. The City recently hired an Internal Auditor, Joan Appiah Yankson, to review City policies and implement standard operating procedures 2. Resource and Training Enhancements: Standard operating procedures are being implemented along with additional staffing and training to support the timely completion of audit reports. Contact: Dr. Kristy Samperi, Controller, Ongoing

Prior Finding References

2023-004

About Reporting →
2024-006
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. Condition: During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

About Procurement and Suspension and Debarment →
2024-007
Reporting
SIGNIFICANT DEFICIENCY

During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

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Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria: 2 CFR 200.303 Internal controls requires the recipient to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program: Coronavirus State and Local Fiscal Recovery Fund Finding: Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide reasonable assurance of compliance with Federal statutes, regulations, and award terms. These controls should align with GAO's Standards for Internal Control in the Federal Government and COSO's Internal Control – Integrated Framework. Condition: The City did not maintain documentation supporting the internal control process over the submission of required quarterly reports during fiscal year 2024. Corrective Actions Taken: 1. Establishment of Formal Reporting Controls: The City has developed and implemented a standardized procedure for the preparation, review, and submission of all quarterly reports related to federal awards, including a designated checklist and approval workflow to ensure compliance with reporting deadlines and content accuracy. 2. Documentation and Retention Protocols: All steps in the reporting process are now formally documented, including preparer and reviewer signoffs. Supporting documentation is retained in a centralized location accessible to relevant staff and auditors for verification purposes. 3. Internal Review and Oversight: The Office of Management, Policy, and Grants has assigned responsibility to the Grant Management Team for conducting secondary reviews of quarterly report submissions. This includes validating that internal controls have been followed, and evidence of compliance is documented. 4. Staff Training: Staff involved in federal reporting have received training on the internal control requirements outlined in 2 CFR 200.303, COSO, and GAO Green Book standards to reinforce the importance of documentation and control procedures. 5. Monitoring and Compliance Checks: A quarterly compliance checklist and review process have been instituted to ensure ongoing adherence to federal internal control requirements. Noncompliance will be flagged and reviewed with senior leadership. Contact: Shannon McCue, Director of Management, Policy, and Grant Anticipated Completion Date: January 2026

About Reporting →

FY 2024-06-30

LOW-RISK AUDITEE$4,474,672 federal awards expended

FAC accepted this audit on March 26, 2025 — management decision was due September 26, 2025.

2024-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003OTHER MATTERS

Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

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Assistance Listing Program Title and Number: Lead Hazard Reduction Grant Program 14.900 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: N/A Award year: Various Criteria or specific requirement: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022 to June 30, 2023 by January 10, 2024. Condition: Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-002: Significant Deficiency and Noncompliance Finding, Reporting-Annual Program: Lead-Based Paint Hazard Reduction Grant Program Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022, to June 30, 2023, by January 10, 2024. Based on our testing of the required quarterly and annual reports we determined the annual report was not submitted as required. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy has been implemented with centralized tracking to monitor grant reporting deadlines and prevent missed submissions. 2. The Office of Management, Policy, and Grants is establishing a Grant Management Team to conduct a secondary review of all reporting-related entries and ensure timely submissions. These actions will be implemented by the end of the next fiscal year, with all policy updates and training completed by October 31, 2025. 3. Health Department: The Health Department and the City’s Internal Auditor are creating Standard Operation Procedures and will train staff by December 31, 2025. 4. Contacts: Shannon McCue, Director of Management, Policy, and Grants; Maritza Bond, Health Director, Anticipated Completion Date: January 2026

Prior Finding References

2023-003

About Reporting →
2024-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Coronavirus State and Local Fiscal Recovery Funds Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally funded projects, it does not maintain formal documentation that this procedure occurred. Corrective Actions Taken: 1. Develop Standard Documentation: Create a standardized verification form or checklist for suspension and debarment checks. Include fields for date, method of verification (e.g., SAM.gov search), name of reviewer, and signature. 2. Integrate into Procurement Workflow: Require completion and attachment of the verification form to all federally funded purchase orders and contracts before approval. Embed verification as a required step in MUNIS or other procurement software workflows, if possible. 3. Staff Training: Provide refresher training for purchasing and finance staff on federal compliance requirements, including suspension and debarment procedures. Emphasize the importance of documentation for audit and compliance purposes. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

About Procurement and Suspension and Debarment →
2024-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Without documented evidence verifying whether the City was following its policy, the City could not provide evidence of this control being completed for federally funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Corrective Actions Taken: 1. Establish Documentation Protocols: The City is implementing standard templates and procedures for verifying suspension and debarment status, including documentation requirements. 2. System Integration and Workflow Updates: These procedures will be integrated into procurement workflows and reviewed regularly to ensure consistency across all federally funded contracts. 3. Monitoring and Oversight: A designated staff member will perform periodic reviews to confirm verification procedures are being followed and properly documented. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-005
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-004OTHER MATTERS

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

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Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

Corrective Action Plan

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023, and June 30, 2022. Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed, and the data collection form and reporting package should be submitted within 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023, and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024, and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late. Corrective Actions Taken: 1. Improved Reporting Processes: The City has streamlined the audit reporting process through enhanced coordination with auditors and improvements to internal procedures. The City recently hired an Internal Auditor, Joan Appiah Yankson, to review City policies and implement standard operating procedures 2. Resource and Training Enhancements: Standard operating procedures are being implemented along with additional staffing and training to support the timely completion of audit reports. Contact: Dr. Kristy Samperi, Controller, Ongoing

Prior Finding References

2023-004

About Reporting →
2024-006
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. Condition: During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-007
Reporting
SIGNIFICANT DEFICIENCY

During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

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Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria: 2 CFR 200.303 Internal controls requires the recipient to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program: Coronavirus State and Local Fiscal Recovery Fund Finding: Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide reasonable assurance of compliance with Federal statutes, regulations, and award terms. These controls should align with GAO's Standards for Internal Control in the Federal Government and COSO's Internal Control – Integrated Framework. Condition: The City did not maintain documentation supporting the internal control process over the submission of required quarterly reports during fiscal year 2024. Corrective Actions Taken: 1. Establishment of Formal Reporting Controls: The City has developed and implemented a standardized procedure for the preparation, review, and submission of all quarterly reports related to federal awards, including a designated checklist and approval workflow to ensure compliance with reporting deadlines and content accuracy. 2. Documentation and Retention Protocols: All steps in the reporting process are now formally documented, including preparer and reviewer signoffs. Supporting documentation is retained in a centralized location accessible to relevant staff and auditors for verification purposes. 3. Internal Review and Oversight: The Office of Management, Policy, and Grants has assigned responsibility to the Grant Management Team for conducting secondary reviews of quarterly report submissions. This includes validating that internal controls have been followed, and evidence of compliance is documented. 4. Staff Training: Staff involved in federal reporting have received training on the internal control requirements outlined in 2 CFR 200.303, COSO, and GAO Green Book standards to reinforce the importance of documentation and control procedures. 5. Monitoring and Compliance Checks: A quarterly compliance checklist and review process have been instituted to ensure ongoing adherence to federal internal control requirements. Noncompliance will be flagged and reviewed with senior leadership. Contact: Shannon McCue, Director of Management, Policy, and Grant Anticipated Completion Date: January 2026

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FY 2024-06-30

$145,677,421 federal awards expended

FAC accepted this audit on June 26, 2025 — management decision was due December 26, 2025.

2024-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003OTHER MATTERS

Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

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Assistance Listing Program Title and Number: Lead Hazard Reduction Grant Program 14.900 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: N/A Award year: Various Criteria or specific requirement: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022 to June 30, 2023 by January 10, 2024. Condition: Based on our testing of required quarterly and annual reports we determined the annual report was not submitted as required. Context: There was one annual report required to be submitted during the audit period that was not filed by the January 10, 2024 deadline. Other required quarterly reporting was filed timely. Cause: City employees responsible for grant management and reporting missed the required submission of the annual report. The City did not have sufficient internal controls in place to ensure all reports were filed as required. Effect: The report should be submitted by the deadline. This results in non-compliance with certain provisions of the reporting requirements of the program. This can result in the Federal government cancelling funding of the program or denying eligible expenditures. Questioned Cost: None Repeating Finding: Yes Recommendation We recommend that the City implement controls to ensure all compliance requirements are complied with as well as contact the grantor about whether or not the delinquent reports should still be filed. Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-002: Significant Deficiency and Noncompliance Finding, Reporting-Annual Program: Lead-Based Paint Hazard Reduction Grant Program Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2022, to June 30, 2023, by January 10, 2024. Based on our testing of the required quarterly and annual reports we determined the annual report was not submitted as required. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy has been implemented with centralized tracking to monitor grant reporting deadlines and prevent missed submissions. 2. The Office of Management, Policy, and Grants is establishing a Grant Management Team to conduct a secondary review of all reporting-related entries and ensure timely submissions. These actions will be implemented by the end of the next fiscal year, with all policy updates and training completed by October 31, 2025. 3. Health Department: The Health Department and the City’s Internal Auditor are creating Standard Operation Procedures and will train staff by December 31, 2025. 4. Contacts: Shannon McCue, Director of Management, Policy, and Grants; Maritza Bond, Health Director, Anticipated Completion Date: January 2026

Prior Finding References

2023-003

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2024-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 20 out of 20 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-003: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Coronavirus State and Local Fiscal Recovery Funds Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally funded projects, it does not maintain formal documentation that this procedure occurred. Corrective Actions Taken: 1. Develop Standard Documentation: Create a standardized verification form or checklist for suspension and debarment checks. Include fields for date, method of verification (e.g., SAM.gov search), name of reviewer, and signature. 2. Integrate into Procurement Workflow: Require completion and attachment of the verification form to all federally funded purchase orders and contracts before approval. Embed verification as a required step in MUNIS or other procurement software workflows, if possible. 3. Staff Training: Provide refresher training for purchasing and finance staff on federal compliance requirements, including suspension and debarment procedures. Emphasize the importance of documentation for audit and compliance purposes. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the City did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the City has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the City makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the City was followings its policy, the City could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 9 out of 9 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the City implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-004: Material Weakness and Noncompliance Finding- Procurement and Suspension, and Debarment - Verification Against the System for Award Management (SAM) Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Without documented evidence verifying whether the City was following its policy, the City could not provide evidence of this control being completed for federally funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Corrective Actions Taken: 1. Establish Documentation Protocols: The City is implementing standard templates and procedures for verifying suspension and debarment status, including documentation requirements. 2. System Integration and Workflow Updates: These procedures will be integrated into procurement workflows and reviewed regularly to ensure consistency across all federally funded contracts. 3. Monitoring and Oversight: A designated staff member will perform periodic reviews to confirm verification procedures are being followed and properly documented. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-005
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-004OTHER MATTERS

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

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Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023 and June 30, 2022. Criteria/Context: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition/Finding: The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023 and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024 and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late Context: The Single Audit Reporting Package and the data collection form for fiscal year 2022 were submitted to the single audit clearing house on August 15, 2023. The fiscal 2023 Single Audit Reporting Package and data collection form were submitted on September 12, 2024. The fiscal 2024 Single Audit Reporting Package and data collection form will likely be submitted after June 15, 2025. Cause: The cause is the lack of effective controls over financial reporting which resulted in delays in issuing both the Financial Statement Audit and Single Audit. Effect or Potential Effect: This can result in errors reported in the SEFA, SESA, or basic financial statements or the disallowance of expenditures / future awards by the grantor due to lack of proper reporting. In addition, late filings result in noncompliance with the requirements of the Uniform Guidance and makes the City ineligible for consideration as a low risk auditee under Uniform Guidance, expanding the scope and cost of the single audit. Recommendation: We recommend the City evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the single audit reporting package and data collection form. Views of Responsible Officials: Management agrees with the finding and recommendation. Questioned Costs: None Repeat Finding: Yes.

Corrective Action Plan

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023, and June 30, 2022. Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed, and the data collection form and reporting package should be submitted within 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023, and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024, and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late. Corrective Actions Taken: 1. Improved Reporting Processes: The City has streamlined the audit reporting process through enhanced coordination with auditors and improvements to internal procedures. The City recently hired an Internal Auditor, Joan Appiah Yankson, to review City policies and implement standard operating procedures 2. Resource and Training Enhancements: Standard operating procedures are being implemented along with additional staffing and training to support the timely completion of audit reports. Contact: Dr. Kristy Samperi, Controller, Ongoing

Prior Finding References

2023-004

About Reporting →
2024-006
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

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Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Assistance Listing Program Title and Number- Lead Hazard Reduction Program 14.900 Federal Agency- Department of Housing and Urban Development Pass-through Entity- N/A Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. Condition: During our audit, we noted that the City did not have the bid documentation for one of our selections. Cause: While the City has a formal policy requiring the purchasing department to maintain all bid documentation it could not locate the one selection. Effect: Without documented evidence the City could not provide evidence of this control being completed. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 1 out of 8 selections tested. Repeating Finding: No Recommendation: We recommend that the City enforce its policy to maintain all procurement documentation. Views of responsible officials of the auditee: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

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2024-007
Reporting
SIGNIFICANT DEFICIENCY

During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

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Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- N/A Criteria: 2 CFR 200.303 Internal controls requires the recipient to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that the City did not have documentation to support that the control over the submission of the quarterly reports operated during fiscal year 2024. Questioned Cost: None Context: See “Condition” above. There was no documentation available for 2 out of the 2 reports selected. However, reports were submitted timely. Effect: No direct effect can be determined. Cause: While the department noted there was segregation of duties in terms of who prepared and reviewed the reports prior to submission, it does not maintain formal documentation that this occurred. Repeat Finding: No Recommendation: We recommend that the City implement a policy to formally document the controls they are performing. Management’s Response/Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program: Coronavirus State and Local Fiscal Recovery Fund Finding: Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide reasonable assurance of compliance with Federal statutes, regulations, and award terms. These controls should align with GAO's Standards for Internal Control in the Federal Government and COSO's Internal Control – Integrated Framework. Condition: The City did not maintain documentation supporting the internal control process over the submission of required quarterly reports during fiscal year 2024. Corrective Actions Taken: 1. Establishment of Formal Reporting Controls: The City has developed and implemented a standardized procedure for the preparation, review, and submission of all quarterly reports related to federal awards, including a designated checklist and approval workflow to ensure compliance with reporting deadlines and content accuracy. 2. Documentation and Retention Protocols: All steps in the reporting process are now formally documented, including preparer and reviewer signoffs. Supporting documentation is retained in a centralized location accessible to relevant staff and auditors for verification purposes. 3. Internal Review and Oversight: The Office of Management, Policy, and Grants has assigned responsibility to the Grant Management Team for conducting secondary reviews of quarterly report submissions. This includes validating that internal controls have been followed, and evidence of compliance is documented. 4. Staff Training: Staff involved in federal reporting have received training on the internal control requirements outlined in 2 CFR 200.303, COSO, and GAO Green Book standards to reinforce the importance of documentation and control procedures. 5. Monitoring and Compliance Checks: A quarterly compliance checklist and review process have been instituted to ensure ongoing adherence to federal internal control requirements. Noncompliance will be flagged and reviewed with senior leadership. Contact: Shannon McCue, Director of Management, Policy, and Grant Anticipated Completion Date: January 2026

About Reporting →

FY 2023-06-30

$1,267,901 federal awards expended

FAC accepted this audit on January 30, 2024 — management decision was due July 30, 2024.

2023-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

During our audit, we noted that the Town did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the Town has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the Town makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the Town was followings its policy, the Town could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 13 out of 13 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the Town implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: The Town agrees with the finding and the recommendation.

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Finding 2023-001 - Procurement and Suspension, and Debarment - Internal Control over Verification Against the System for Award Management (“SAM”) Assistance Listing Program Title and Number- Coronavirus State and Local Fiscal Recovery Funds 21.027 Federal Agency- Department of Treasury Pass-through Entity- State Office of Policy and Management, State Department of Education Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: During our audit, we noted that the Town did not have documentation to support that it verified vendors selected for testing against the SAM to ensure that they were not suspended or debarred from federally— funded purchases. Cause: While the Town has a formal policy requiring the purchasing department to perform verification of suspension or debarment over vendors that the Town makes contracts with federally-funded projects, it does not maintain formal documentation that this procedure occurred. Effect: Without documented evidence of verifying whether the Town was followings its policy, the Town could not provide evidence of this control was being completed for federally-funded projects. There were no standard forms or templates that were used to document verification that parties are not suspended or debarred. Questioned Cost: None Context: See condition above for context for the finding. There was no documentation available for 13 out of 13 selections tested. However, none of the vendors selected for testing were suspended or debarred. Repeating Finding: No Recommendation: We recommend that the Town implement a policy to formally document the procedures they are performing. Views of responsible officials of the auditee: The Town agrees with the finding and the recommendation.

Corrective Action Plan

The Town will adopt a formal policy to document and identify suspended and disbarred vendors and review the System for Award Management (SAM) for such vendors before engaging with a vendor in a project that uses federal funds including ARP funds. We will document, with email and other evidence, that such steps have been taken.

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