CITY OF ST. LOUIS MUNICIPAL LIBRARY DISTRICT

Finding 2023-001 Significant Deficiency: Equipment and Real Property Management – Control and Compliance Finding; Special Test and Control Provisions - Control and Compliance Finding ALN 32.009 – Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require the dates the device or other piece of equipment was loaned out and returned to the school or library, or the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged be retained for program records. The provisions also restricts use to no more than one connected device per patron and no more than one fixed broadband connection per location, and requires that equipment only be provided to patrons who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed application related to the checking out of either a hotspot or Chromebook offered by the Library was not retained or completed correctly. This application should be retained and used to determine eligibility and proper inclusion in the system. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements and therefore the compliance with equipment and real property and special tests and provision requirements were not met. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by the Library were to ensure patrons signed and properly completed the relevant application depending on the type of equipment requested. A signed application was not retained for 8 of 40 checkouts tested for equipment and real property and special test and provision requirements, and 2 of 40 applications appeared to not have been properly filled out. Identification As A Repeat Finding: 2022-001 Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: Management continues to implement tightened procedures and train staff to assure that all applications are completed, signed, dated and retained correctly for any equipment loaned to Library patrons.

Finding No. 2023-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions

2022-001

Finding 2023-002 Significant Deficiency: Special Tests and Provisions – Control and Compliance Finding ALN 32.009 – Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program restricts use to no more than one connected device per patron and no more than one fixed broadband connection per location. Provision also requires that equipment only be provided to patrons who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to service and equipment inventory requirements. Condition: Out of 40 patrons selected for testing checked out equipment, three patrons were noted as checking out two or more Chromebooks during the year with no proof of return for the first Chromebook. Upon investigation by the Library, one of the patrons claimed a Chromebook was returned, but no record of that return is noted within the system, one patron noted that they only checked out the most recent Chromebook based on the system, and another patron was actually an employee of the Library that was checking out the Chromebooks for the Library’s outreach program. For those three patrons, applications could not be found by the Library. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements and therefore there was no compliance with special tests and provisions. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by the Library were to ensure equipment that is loaned to the Library’s patron is properly recorded in the system and tracked through the return process were not operating effectively. Of the 40 patrons tested, verification that the three patrons did not have more than one Chromebook at a time could not be completed. Identification As A Repeat Finding: 2022-002 Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: Management will review with staff the revised procedures to assure that all records of loan equipment are accurate based on the retained signed applications and electronic transaction history.

Finding No. 2023-002 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2024 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions

2022-002

Finding 2022-001 Significant Deficiency: Equipment and Real Property Management ? Control and Compliance Finding; Special Test and Control Provisions - Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed application related to the checking out of either a hotspot or Chromebook offered by the Library was not retained. This application should be retained and information used to determine eligibility and proper inclusion in the system. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements and therefore the compliance with equipment and real property and special tests and provision requirements were not met. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by the Library were to ensure patrons signed the relevant application depending on the type of equipment requested. A signed application was not retained for 4 of 40 patrons tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: Management will review current procedures and implement tightened procedures to assure that all applications are completed, signed, dated and retained correctly for any equipment loan to Library patrons.

Finding No. 2022-001 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions.

Finding 2022-002 Significant Deficiency: Equipment and Real Property Management ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require the dates the device or other piece of equipment was loaned out and returned to the school or library, or the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged be retained for program records. Provisions of the federal program also restrict use to no more than one connected device per patron and no more than one fixed broadband connection per location. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to service and equipment inventory requirements. Condition: For one of 40 patrons that had checked out equipment, one patron was noted as checking out two Chromebooks during the year. Upon investigation by the Library, the patron claimed a Chromebook was returned, but no record of that return is noted within the system. The Library shut off all connectivity to the Chromebook within their system. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements and therefore there was no compliance with the recording and maintenance of equipment and real property and with special tests and provisions. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by the Library were to ensure equipment that is loaned to the Library?s patron is properly recorded in the system and tracked through the return process were not operating effectively. Of the 40 patrons tested, 1 patron noted that equipment, specifically a Chromebook, was returned but the Library has no proof of such return. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: Management will strengthen and implement revised procedures to assure that all records of loan equipment are accurate based on the retained signed applications and electronic transaction history.

Finding No. 2022-002 Significant Deficiency Personnel Responsible for Corrective Action: Jim Slattery, Chief Financial Officer Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management for the St. Louis Public library will review all processes associated with checking out equipment and make necessary revisions to processes and procedures to ensure all staff are properly trained to successfully execute all transactions.