University of Maryland Medical System CorporationNon-Profit

Finding Reference: 2025-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Justice Awards: Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: July 1, 2024 – September 30, 2026 Description: Review and Approval of Payroll Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of certain payroll expenditures that were included in the Department of Justice (DOJ) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of certain timecards and cost allocation schedules reported to the DOJ in the required submissions. Effect or potential effect The related payroll expenditures included in the DOJ submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual payroll expenditures, management reviews and approves these expenditures as part of the payroll process, specifically the review and approval of timecards and cost allocation schedules. In conjunction with our testing related to allowability, we selected a sample of payroll expenditures to test management’s review and approval of expenditures as part of the payroll process. In accordance with the Corporation’s payroll process, timecards and cost allocation schedules must be reviewed and approved for determining allowability of these payroll expenditures prior to submitting reports to the DOJ. There were six payroll expenditures totaling $5,828, or approximately 9% of our population; that did not have a timecard approval or approval of their cost allocation schedule. Based on review of the timecards and cost allocation schedules for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program. Recommendation Management should retain documentation that evidences the review and approval of expenditures submitted to the DOJ. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2025-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Evidence of Review and Approval of the Reported Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program ALN 16.753 includes two sub-vendor contracts between the granting agency, Department of Justice (DOJ) and UMMS for the University of Maryland Medical Center (UMMC) Byrne Trauma Clinic and the University of Maryland Capital Region Medical Center (UMCAP) Byrne Discretionary Community. The major program ALN 93.078 includes two sub-vendor contracts between the granting agency, Department of Health and Human Services (DHHS) and UMMS for the ASPR Mission Zero. Condition The Corporation did not have appropriately designed internal controls in place over the grant subawards related to review and approval of the expenditures that were included in the DOJ and DHHS submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to the DOJ or DHHS in the required submissions for cash reimbursement and reporting. Effect or potential effect The expenditures included in the DOJ or DHHS submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context For the major program ALN 16.753 quarterly cash reimbursement, quarterly financial report and semi-annual progress report submissions, management did not retain documentation to evidence review and approval of the submitted reports and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. For the major program ALN 93.078 annual cash reimbursement and financial report, management did not retain documentation to evidence review and approval of the submitted reports and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the DOJ and DHHS for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2025-003 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Incomplete Federal Requirements within Procurement Policies Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Part 200.320 Methods of procurement to be followed states the following: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319” regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have a procurement policy that conforms to all applicable standards contained in the Uniform Guidance, when purchasing goods or services with the federal funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to their federal programs. Effect or potential effect Purchasing of goods and/or servicing with the major federal programs may not be in compliance with the Uniform Guidance. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2024-006. Context Management has not established a procurement policy in line with the applicable standards contained in the Uniform Guidance based on review of the existing policy and discussions with management, however, no other instances of noncompliance with procurement standards identified in 2 CFR part 200 were noted as the amount of purchases exceeding the micro-purchase threshold was not direct and material to these programs and therefore no further testing over procurement was performed. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2025-004 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Evidence of controls over Suspension and Debarment Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have appropriately designed internal controls in order to retain evidence related to the completeness and accuracy of the vendor list and monthly results for suspension and debarment. The Corporation validates that vendors are reviewed on a monthly basis to ensure they are not included on the suspension and debarment list. There was no documentation retained to support the vendor list and results were complete and accurate for the monthly validation. Cause The Corporation did not retain sufficient evidence to support the completeness and accuracy of the vendor list and results for suspension and debarment. Effect or potential effect The vendor list and monthly results for suspension and debarment may not be complete and accurate and therefore, vendors used for federally funded activities may be suspended or debarred and result in noncompliance with the requirement. Questioned costs None. Identification of a repeat finding This is a repeat finding of 2024-007. Context As part of the suspension and debarment testing, we did not identify any vendors that were excluded from the vendor list, monthly results or included within the suspension and debarment list. Management retained evidence of the monthly review including their documentation of follow ups on any vendors that required further investigation. Recommendation The Corporation should retain documentation to support completeness and accuracy of the vendor list submitted for screening and the results obtained to support the screening process to ensure that no suspended or debarred vendors are utilized by the Corporation prior to entering into transactions. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Review and Approval of Purchase Orders Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the purchase orders that were included in the Behavioral Health System Baltimore, Inc. (BHSB) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of purchase orders reported to BHSB in the required submissions.   Effect or potential effect The expenditures included in the BHSB submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual expenditures, management reviews and approves expenditures as part of the purchasing and payables business process, specifically the review and approval purchase orders. In conjunction with our testing related to the submissions and allowability, we selected a sample of expenditures to test management’s review and approval of expenditures as part of the purchasing and payables business process. In accordance with the Corporation’s purchasing and payables business process, vendor specific purchase orders must be reviewed and approved prior to the payment of the invoices. There were six purchase orders totaling $18,052, or approximately 5% of our population, that did not have approval. These purchase orders were isolated to one vendor for purchases that is set up under the Corporation’s group purchasing process, which did not always require a segregation between the requisitioner and approver during the grant period. The purchases from our testing that did not have an approval, all occurred subsequent to March 2024, which is when the employee turnover occurred, and a new approver was not designated yet. As a result, the respective orders did not route for approval as the purchase order was submitted by the previous approver. Based on review of the purchase order and invoice for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program.   Recommendation Management should obtain documentation that evidences the review and approval of expenditures submitted to BHSB. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Review and Approval of Purchase Orders Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the purchase orders that were included in the Behavioral Health System Baltimore, Inc. (BHSB) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of purchase orders reported to BHSB in the required submissions. Effect or potential effect The expenditures included in the BHSB submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual expenditures, management reviews and approves expenditures as part of the purchasing and payables business process, specifically the review and approval purchase orders. In conjunction with our testing related to the submissions and allowability, we selected a sample of expenditures to test management’s review and approval of expenditures as part of the purchasing and payables business process. In accordance with the Corporation’s purchasing and payables business process, vendor specific purchase orders must be reviewed and approved prior to the payment of the invoices. There were six purchase orders totaling $18,052, or approximately 5% of our population, that did not have approval. These purchase orders were isolated to one vendor for purchases that is set up under the Corporation’s group purchasing process, which did not always require a segregation between the requisitioner and approver during the grant period. The purchases from our testing that did not have an approval, all occurred subsequent to March 2024, which is when the employee turnover occurred, and a new approver was not designated yet. As a result, the respective orders did not route for approval as the purchase order was submitted by the previous approver. Based on review of the purchase order and invoice for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program. Recommendation Management should obtain documentation that evidences the review and approval of expenditures submitted to BHSB. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Evidence of Review and Approval of the Reported Expenditures and Timely Report Submission Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”   The major program includes two sub-vendor contracts between the granting agency, BHSB and the University of Maryland Medical Center (UMMC) for the OUD MEETS Medical Patient Engagement – OTP and OUD MEETS Medical Patient Engagement – Hospital programs. In accordance with both subaward contract terms within Section 2, Financial Reporting and Payment for Services, “invoices are due by the 15th day of the month following the invoice period.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the expenditures that were included in the BHSB submissions and timeliness of the submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to BHSB in the required submissions nor were all submissions made with the required 15-day period. Effect or potential effect The expenditures included in the BHSB submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding.   Context On a monthly basis, the expenditures are compiled and reconciled to the cash reimbursement request and internal tracking spreadsheet. The Corporation submitted a total of 24 BHSB cash reimbursement submissions for the subawards. The total payments received by the Corporation was $352,026. During the last quarter of the grant period, there were changes in employee responsibilities due to employee turnover. Specific to the last quarter of the grant period, for the related monthly BHSB cash reimbursement submissions and the 440 annual financial report submissions, management did not retain documentation to evidence review and approval of the expenditures requested for cash reimbursement. The total expenditures submitted for reimbursement were $111,705 or approximately 32% for the last quarter of the grant period. As part of our testing, we selected 10 out of the 24 BHSB cash reimbursement submissions throughout the grant period, and 9 out of the 10 submissions were not submitted timely. We agreed the ten samples to supporting underlying documentation for each of these selections totaling $215,208. Three of the ten selections totaling $78,336, were within the last quarter. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Evidence of Review and Approval of the Reported Expenditures and Timely Report Submission Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program includes two sub-vendor contracts between the granting agency, BHSB and the University of Maryland Medical Center (UMMC) for the OUD MEETS Medical Patient Engagement – OTP and OUD MEETS Medical Patient Engagement – Hospital programs. In accordance with both subaward contract terms within Section 2, Financial Reporting and Payment for Services, “invoices are due by the 15th day of the month following the invoice period.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the expenditures that were included in the BHSB submissions and timeliness of the submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to BHSB in the required submissions nor were all submissions made with the required 15-day period. Effect or potential effect The expenditures included in the BHSB submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context On a monthly basis, the expenditures are compiled and reconciled to the cash reimbursement request and internal tracking spreadsheet. The Corporation submitted a total of 24 BHSB cash reimbursement submissions for the subawards. The total payments received by the Corporation were $352,026. During the last quarter of the grant period, there were changes in employee responsibilities due to employee turnover. Specific to the last quarter of the grant period, for the related monthly BHSB cash reimbursement submissions and the 440 annual financial report submissions, management did not retain documentation to evidence review and approval of the expenditures requested for cash reimbursement. The total expenditures submitted for reimbursement were $111,705 or approximately 32% for the last quarter of the grant period. As part of our testing, we selected 10 out of the 24 BHSB cash reimbursement submissions throughout the grant period, and 9 out of the 10 submissions were not submitted timely. We agreed the ten samples to supporting underlying documentation for each of these selections totaling $215,208. Three of the ten selections totaling $78,336, were within the last quarter. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-003 – H. Period of Performance Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Timely Payment of Financial Obligations Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.344(c), Closeout, “The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.” Condition Management’s monitoring control over compliance with applicable period of performance requirements and timely payment of the reported expenditures following their reimbursement from BHSB was not designed appropriately to ensure all expenditures were paid within the specific period of performance.   Cause The Corporation did not process payments to one vendor within the applicable period of performance requirement for federal award expenditures reimbursed by the BHSB. Effect or potential effect The expenditures included in the BHSB submissions are not in compliance with applicable period of performance requirements. Questioned costs $17,151 represents Federal expenditures that remained unpaid or were paid outside of the 120 days following the end date of the period of performance for the following subawards: • 93.959: BH031 - OUD MEETS-OTP-UMMC - $ 3,589 • 93.959: BH031 - OUD MEETS-HOS-UMMC - $13,562 Identification of a repeat finding No. This is not a repeat finding. Context As part of our testing, we selected 25 expenditures. We identified that four selections or $1,695 of the total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. This was isolated to one vendor that is set up under the Corporation’s group purchasing process. As part of our testing, there were $4,362 purchases tested and $36,943 total purchases related to the one vendor within the grant period. Due to complexities of group purchase billing and recording for the vendor, management further investigated and identified that $17,151 of total expenditures within the grant period or approximately 5% of total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. Recommendation As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-003 – H. Period of Performance Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Timely Payment of Financial Obligations Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.344(c), Closeout, “The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.” Condition Management’s monitoring control over compliance with applicable period of performance requirements and timely payment of the reported expenditures following their reimbursement from BHSB was not designed appropriately to ensure all expenditures were paid within the specific period of performance. Cause The Corporation did not process payments to one vendor within the applicable period of performance requirement for federal award expenditures reimbursed by the BHSB. Effect or potential effect The expenditures included in the BHSB submissions are not in compliance with applicable period of performance requirements. Questioned costs $17,151 represents Federal expenditures that remained unpaid or were paid outside of the 120 days following the end date of the period of performance for the following subawards: • 93.959: BH031 - OUD MEETS-OTP-UMMC - $ 3,589 • 93.959: BH031 - OUD MEETS-HOS-UMMC - $13,562 Identification of a repeat finding No. This is not a repeat finding. Context As part of our testing, we selected 25 expenditures. We identified that four selections or $1,695 of the total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. This was isolated to one vendor that is set up under the Corporation’s group purchasing process. As part of our testing, there were $4,362 purchases tested and $36,943 total purchases related to the vendor within the grant period. Due to complexities of group purchase billing and recording for the vendor, management further investigated and identified that $17,151 of total expenditures within the grant period or approximately 5% of total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. Recommendation As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-004 – Other finding – SEFA Preparation Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Preparation of Schedule of Expenditures of Federal Awards Criteria The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare the Schedule for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition The Corporation did not have appropriately designed internal controls in place to determine the correct amount of federal expenditures to be included on the Schedule. The Corporation omitted the expenditures related to the Assistance Listing Number 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds as well as expenditures related to seven other assistance listing numbers. Cause The Corporation did not design internal controls to completely and accurately report expenditures within the Schedule. Effect or potential effect The Schedule prepared by the Corporation was misstated but was subsequently corrected. A misstated Schedule could result in the improper selection of federal award major programs or an incorrect percentage of coverage being calculated resulting in a restatement of a previously issued Uniform Guidance report. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2023-002. Context Expenditures for Assistance Listing 21.027 of approximately $339,000 were excluded from the Schedule. In addition, expenditures totaling approximately $261,000 for seven other assistance listing numbers were also excluded from the Schedule. Recommendation The Corporation should update its policies and procedures and internal controls to ensure accurate reporting of the Schedule as required by the Uniform Guidance. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-005 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of Review and Approval of the Reported Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program Assistance Listing 21.027 includes two sub-vendor contracts between the granting agency, Department of Treasury and UMMS for the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program and MONSE HVIP. Condition The Corporation did not have appropriately designed internal controls in place over the grant subawards related to review and approval of the expenditures that were included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to Baltimore County, Maryland and the Mayor's Office of Neighborhood Safety and Engagement in the required submissions. Effect or potential effect The expenditures included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions could be unallowed costs, inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context For the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program subaward’s annual financial report submission to Baltimore County, Maryland, management did not retain documentation to evidence review and approval of the stipend expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. For the MONSE HVIP subaward’s monthly financial report submissions to the Mayor's Office of Neighborhood Safety and Engagement, management did not retain documentation to evidence review and approval of the fringe and indirect cost rates and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of the stipends, fringe and indirect cost rates and the expenditures submitted to the Department of Treasury for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-006 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Incomplete Federal Requirements within Procurement Policies Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Part 200.320 Methods of procurement to be followed states the following: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319” regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have a procurement policy that conforms to all applicable standards contained in the Uniform Guidance, when purchasing goods or services with the federal funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to their federal programs. Effect or potential effect Purchasing of goods and/or servicing with the major federal programs may not be in compliance with the Uniform Guidance. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2023-001. Context Management has not established a procurement policy in line with the applicable standards contained in the Uniform Guidance based on review of the existing policy and discussions with management, however, no other instances of noncompliance with procurement standards identified in 2 CFR part 200 were noted as the amount of purchases exceeding the micro-purchase threshold was not direct and material to this program and therefore no further testing over procurement was performed. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-007 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of controls over Suspension and Debarment Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have appropriately designed internal controls in order to retain evidence related to the completeness and accuracy of the vendor list and monthly results for suspension and debarment. The Corporation validates that vendors are reviewed on a monthly basis to ensure they are not included on the suspension and debarment list. There was no documentation retained to support the vendor list and results were complete and accurate for the monthly validation. Cause The Corporation did not retain sufficient evidence to support the completeness and accuracy of the vendor list and results for suspension and debarment. Effect or potential effect The vendor list and monthly results for suspension and debarment may not be complete and accurate and therefore, vendors used for federally funded activities may be suspended or debarred and result in noncompliance with the requirement. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Context As part of the suspension and debarment testing, we did not identify any vendors that were excluded from the vendor list, monthly results or included within the suspension and debarment list. Management retained evidence of the monthly review including their documentation of follow ups on any vendors that required further investigation. Recommendation The Corporation should retain documentation to support completeness and accuracy of the vendor list submitted for screening and the results obtained to support the screening process to ensure that no suspended or debarred vendors are utilized by the Corporation prior to entering into transactions. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Review and Approval of Purchase Orders Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the purchase orders that were included in the Behavioral Health System Baltimore, Inc. (BHSB) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of purchase orders reported to BHSB in the required submissions.   Effect or potential effect The expenditures included in the BHSB submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual expenditures, management reviews and approves expenditures as part of the purchasing and payables business process, specifically the review and approval purchase orders. In conjunction with our testing related to the submissions and allowability, we selected a sample of expenditures to test management’s review and approval of expenditures as part of the purchasing and payables business process. In accordance with the Corporation’s purchasing and payables business process, vendor specific purchase orders must be reviewed and approved prior to the payment of the invoices. There were six purchase orders totaling $18,052, or approximately 5% of our population, that did not have approval. These purchase orders were isolated to one vendor for purchases that is set up under the Corporation’s group purchasing process, which did not always require a segregation between the requisitioner and approver during the grant period. The purchases from our testing that did not have an approval, all occurred subsequent to March 2024, which is when the employee turnover occurred, and a new approver was not designated yet. As a result, the respective orders did not route for approval as the purchase order was submitted by the previous approver. Based on review of the purchase order and invoice for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program.   Recommendation Management should obtain documentation that evidences the review and approval of expenditures submitted to BHSB. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Review and Approval of Purchase Orders Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the purchase orders that were included in the Behavioral Health System Baltimore, Inc. (BHSB) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of purchase orders reported to BHSB in the required submissions. Effect or potential effect The expenditures included in the BHSB submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual expenditures, management reviews and approves expenditures as part of the purchasing and payables business process, specifically the review and approval purchase orders. In conjunction with our testing related to the submissions and allowability, we selected a sample of expenditures to test management’s review and approval of expenditures as part of the purchasing and payables business process. In accordance with the Corporation’s purchasing and payables business process, vendor specific purchase orders must be reviewed and approved prior to the payment of the invoices. There were six purchase orders totaling $18,052, or approximately 5% of our population, that did not have approval. These purchase orders were isolated to one vendor for purchases that is set up under the Corporation’s group purchasing process, which did not always require a segregation between the requisitioner and approver during the grant period. The purchases from our testing that did not have an approval, all occurred subsequent to March 2024, which is when the employee turnover occurred, and a new approver was not designated yet. As a result, the respective orders did not route for approval as the purchase order was submitted by the previous approver. Based on review of the purchase order and invoice for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program. Recommendation Management should obtain documentation that evidences the review and approval of expenditures submitted to BHSB. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Evidence of Review and Approval of the Reported Expenditures and Timely Report Submission Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”   The major program includes two sub-vendor contracts between the granting agency, BHSB and the University of Maryland Medical Center (UMMC) for the OUD MEETS Medical Patient Engagement – OTP and OUD MEETS Medical Patient Engagement – Hospital programs. In accordance with both subaward contract terms within Section 2, Financial Reporting and Payment for Services, “invoices are due by the 15th day of the month following the invoice period.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the expenditures that were included in the BHSB submissions and timeliness of the submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to BHSB in the required submissions nor were all submissions made with the required 15-day period. Effect or potential effect The expenditures included in the BHSB submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding.   Context On a monthly basis, the expenditures are compiled and reconciled to the cash reimbursement request and internal tracking spreadsheet. The Corporation submitted a total of 24 BHSB cash reimbursement submissions for the subawards. The total payments received by the Corporation was $352,026. During the last quarter of the grant period, there were changes in employee responsibilities due to employee turnover. Specific to the last quarter of the grant period, for the related monthly BHSB cash reimbursement submissions and the 440 annual financial report submissions, management did not retain documentation to evidence review and approval of the expenditures requested for cash reimbursement. The total expenditures submitted for reimbursement were $111,705 or approximately 32% for the last quarter of the grant period. As part of our testing, we selected 10 out of the 24 BHSB cash reimbursement submissions throughout the grant period, and 9 out of the 10 submissions were not submitted timely. We agreed the ten samples to supporting underlying documentation for each of these selections totaling $215,208. Three of the ten selections totaling $78,336, were within the last quarter. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Evidence of Review and Approval of the Reported Expenditures and Timely Report Submission Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program includes two sub-vendor contracts between the granting agency, BHSB and the University of Maryland Medical Center (UMMC) for the OUD MEETS Medical Patient Engagement – OTP and OUD MEETS Medical Patient Engagement – Hospital programs. In accordance with both subaward contract terms within Section 2, Financial Reporting and Payment for Services, “invoices are due by the 15th day of the month following the invoice period.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of the expenditures that were included in the BHSB submissions and timeliness of the submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to BHSB in the required submissions nor were all submissions made with the required 15-day period. Effect or potential effect The expenditures included in the BHSB submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context On a monthly basis, the expenditures are compiled and reconciled to the cash reimbursement request and internal tracking spreadsheet. The Corporation submitted a total of 24 BHSB cash reimbursement submissions for the subawards. The total payments received by the Corporation were $352,026. During the last quarter of the grant period, there were changes in employee responsibilities due to employee turnover. Specific to the last quarter of the grant period, for the related monthly BHSB cash reimbursement submissions and the 440 annual financial report submissions, management did not retain documentation to evidence review and approval of the expenditures requested for cash reimbursement. The total expenditures submitted for reimbursement were $111,705 or approximately 32% for the last quarter of the grant period. As part of our testing, we selected 10 out of the 24 BHSB cash reimbursement submissions throughout the grant period, and 9 out of the 10 submissions were not submitted timely. We agreed the ten samples to supporting underlying documentation for each of these selections totaling $215,208. Three of the ten selections totaling $78,336, were within the last quarter. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-003 – H. Period of Performance Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Timely Payment of Financial Obligations Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.344(c), Closeout, “The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.” Condition Management’s monitoring control over compliance with applicable period of performance requirements and timely payment of the reported expenditures following their reimbursement from BHSB was not designed appropriately to ensure all expenditures were paid within the specific period of performance.   Cause The Corporation did not process payments to one vendor within the applicable period of performance requirement for federal award expenditures reimbursed by the BHSB. Effect or potential effect The expenditures included in the BHSB submissions are not in compliance with applicable period of performance requirements. Questioned costs $17,151 represents Federal expenditures that remained unpaid or were paid outside of the 120 days following the end date of the period of performance for the following subawards: • 93.959: BH031 - OUD MEETS-OTP-UMMC - $ 3,589 • 93.959: BH031 - OUD MEETS-HOS-UMMC - $13,562 Identification of a repeat finding No. This is not a repeat finding. Context As part of our testing, we selected 25 expenditures. We identified that four selections or $1,695 of the total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. This was isolated to one vendor that is set up under the Corporation’s group purchasing process. As part of our testing, there were $4,362 purchases tested and $36,943 total purchases related to the one vendor within the grant period. Due to complexities of group purchase billing and recording for the vendor, management further investigated and identified that $17,151 of total expenditures within the grant period or approximately 5% of total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. Recommendation As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-003 – H. Period of Performance Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing 93.959 – Block Grants for Substance Use Prevention, Treatment, and Recovery Services Award Periods: June 1, 2023 – June 30, 2024 Description: Timely Payment of Financial Obligations Type of Finding: Compliance and Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.344(c), Closeout, “The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award.” Condition Management’s monitoring control over compliance with applicable period of performance requirements and timely payment of the reported expenditures following their reimbursement from BHSB was not designed appropriately to ensure all expenditures were paid within the specific period of performance. Cause The Corporation did not process payments to one vendor within the applicable period of performance requirement for federal award expenditures reimbursed by the BHSB. Effect or potential effect The expenditures included in the BHSB submissions are not in compliance with applicable period of performance requirements. Questioned costs $17,151 represents Federal expenditures that remained unpaid or were paid outside of the 120 days following the end date of the period of performance for the following subawards: • 93.959: BH031 - OUD MEETS-OTP-UMMC - $ 3,589 • 93.959: BH031 - OUD MEETS-HOS-UMMC - $13,562 Identification of a repeat finding No. This is not a repeat finding. Context As part of our testing, we selected 25 expenditures. We identified that four selections or $1,695 of the total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. This was isolated to one vendor that is set up under the Corporation’s group purchasing process. As part of our testing, there were $4,362 purchases tested and $36,943 total purchases related to the vendor within the grant period. Due to complexities of group purchase billing and recording for the vendor, management further investigated and identified that $17,151 of total expenditures within the grant period or approximately 5% of total expenditures remained unpaid or were paid outside of the 120 days from the end of the period of performance or June 30, 2024. Recommendation As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-004 – Other finding – SEFA Preparation Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Preparation of Schedule of Expenditures of Federal Awards Criteria The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare the Schedule for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition The Corporation did not have appropriately designed internal controls in place to determine the correct amount of federal expenditures to be included on the Schedule. The Corporation omitted the expenditures related to the Assistance Listing Number 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds as well as expenditures related to seven other assistance listing numbers. Cause The Corporation did not design internal controls to completely and accurately report expenditures within the Schedule. Effect or potential effect The Schedule prepared by the Corporation was misstated but was subsequently corrected. A misstated Schedule could result in the improper selection of federal award major programs or an incorrect percentage of coverage being calculated resulting in a restatement of a previously issued Uniform Guidance report. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2023-002. Context Expenditures for Assistance Listing 21.027 of approximately $339,000 were excluded from the Schedule. In addition, expenditures totaling approximately $261,000 for seven other assistance listing numbers were also excluded from the Schedule. Recommendation The Corporation should update its policies and procedures and internal controls to ensure accurate reporting of the Schedule as required by the Uniform Guidance. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-005 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of Review and Approval of the Reported Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program Assistance Listing 21.027 includes two sub-vendor contracts between the granting agency, Department of Treasury and UMMS for the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program and MONSE HVIP. Condition The Corporation did not have appropriately designed internal controls in place over the grant subawards related to review and approval of the expenditures that were included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to Baltimore County, Maryland and the Mayor's Office of Neighborhood Safety and Engagement in the required submissions. Effect or potential effect The expenditures included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions could be unallowed costs, inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context For the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program subaward’s annual financial report submission to Baltimore County, Maryland, management did not retain documentation to evidence review and approval of the stipend expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. For the MONSE HVIP subaward’s monthly financial report submissions to the Mayor's Office of Neighborhood Safety and Engagement, management did not retain documentation to evidence review and approval of the fringe and indirect cost rates and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of the stipends, fringe and indirect cost rates and the expenditures submitted to the Department of Treasury for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-006 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Incomplete Federal Requirements within Procurement Policies Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Part 200.320 Methods of procurement to be followed states the following: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319” regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have a procurement policy that conforms to all applicable standards contained in the Uniform Guidance, when purchasing goods or services with the federal funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to their federal programs. Effect or potential effect Purchasing of goods and/or servicing with the major federal programs may not be in compliance with the Uniform Guidance. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2023-001. Context Management has not established a procurement policy in line with the applicable standards contained in the Uniform Guidance based on review of the existing policy and discussions with management, however, no other instances of noncompliance with procurement standards identified in 2 CFR part 200 were noted as the amount of purchases exceeding the micro-purchase threshold was not direct and material to this program and therefore no further testing over procurement was performed. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2024-007 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of controls over Suspension and Debarment Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have appropriately designed internal controls in order to retain evidence related to the completeness and accuracy of the vendor list and monthly results for suspension and debarment. The Corporation validates that vendors are reviewed on a monthly basis to ensure they are not included on the suspension and debarment list. There was no documentation retained to support the vendor list and results were complete and accurate for the monthly validation. Cause The Corporation did not retain sufficient evidence to support the completeness and accuracy of the vendor list and results for suspension and debarment. Effect or potential effect The vendor list and monthly results for suspension and debarment may not be complete and accurate and therefore, vendors used for federally funded activities may be suspended or debarred and result in noncompliance with the requirement. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Context As part of the suspension and debarment testing, we did not identify any vendors that were excluded from the vendor list, monthly results or included within the suspension and debarment list. Management retained evidence of the monthly review including their documentation of follow ups on any vendors that required further investigation. Recommendation The Corporation should retain documentation to support completeness and accuracy of the vendor list submitted for screening and the results obtained to support the screening process to ensure that no suspended or debarred vendors are utilized by the Corporation prior to entering into transactions. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing Number 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2021 – June 30, 2023 Description: Incomplete Federal Requirements within Procurement Policies Type of Finding: Compliance and Deficiency in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Part 200.320 Methods of procurement to be followed states the following: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319" regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for Coronavirus State and Local Fiscal Recovery Funds, we noted that the Corporation did not have a procurement policy that conforms to all applicable Federal law, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the Coronavirus State and Local Fiscal Recovery Funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to the Coronavirus State and Local Fiscal Recovery Funds program. Effect or potential effect Purchasing of goods and/or servicing with the State and Local Fiscal Recovery Funds may not be in compliance with the Uniform Guidance. Questioned costs Not applicable. Identification of a repeat finding This is a repeat finding of Finding 2022-001 in the prior year. Context The Corporation utilized the funds awarded to their facility to bolster staff and entered into various labor contracts with agency vendors. As a result of the pandemic and related public emergency, there was an unprecedented stress on the labor force and therefore, a high demand and dependency on agency labor. As part of management’s assessment, a competitive solicitation would have resulted in a delay and lack of required and necessary staff. As such, this specific circumstance would allow for noncompetitive procurement. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials The Corporation agrees with the finding and has developed a plan to correct the finding.

Finding Reference: 2023-002 – Other Federal Program Information Federal Agencies: Department of Homeland Security Awards: Assistance Listing Number 97.036 – COVID-19 – Disaster Grants – Public Assistances (Presidentially Declared Disasters) Award Periods: February 4, 2020 – Ongoing Description: Reporting of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition On the preliminary Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2023, the Corporation did not include all expenditures related to Assistance Listing Number 97.036 – COVID-19 – Disaster Grants – Public Assistances (Presidentially Declared Disasters). Cause The Schedule for the year ended June 30, 2023 included a number of COVID 19 programs. These programs did not follow the historical grant process and therefore, various individuals in the Corporation were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. Management continued to enhance procedures related to preparation and assessment of the Schedule. However, Assistance Listing Number 97.036 – COVID-19 – Disaster Grants – Public Assistances (Presidentially Declared Disasters) did not include all incurred and obligated expenditures for the year ended June 30, 2023. Effect or potential effect This condition resulted in a net understatement of expenditures in the amount of $2,911,434 for the program on the preliminary Schedule due to incomplete reporting and verification of the completeness and accuracy of the expenditures. Questioned costs None. Identification of a repeat finding No. Context The Corporation reports expenditures on the Schedule using the accrual basis of accounting. As part of our review of the Schedule, we identified that expenditures were erroneously excluded from the preliminary Schedule based on the dates the expenditures were incurred and obligated. Recommendation The Corporation’s policy and procedures should be designed to ensure expenditures are reported on the Schedule based on the date on which the expenditures are incurred as required by the Uniform Guidance. View of responsible officials There is no disagreement with the audit finding.

Section III ? Federal Award Findings and Questioned Costs Finding Reference: 2022-001 ? I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing Number 21.027 ? COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Award Periods: March 17, 2022 ? Ongoing Description: Incomplete Federal Requirements within Procurement Policies Type of Finding: Deficiency in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Part 200.320 Methods of procurement to be followed states the following: ?The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319" regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for Coronavirus State and Local Fiscal Recovery Funds, we noted that the Corporation did not have a procurement policy that conforms to all applicable Federal law, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the Coronavirus State and Local Fiscal Recovery Funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to the Coronavirus State and Local Fiscal Recovery Funds program. Effect or potential effect Purchasing of goods and/or servicing with the State and Local Fiscal Recovery Funds may not be in compliance with the Uniform Guidance. Questioned costs Not applicable. Identification of a repeat finding This is not a repeat finding. Context The Corporation utilized the funds awarded to their facility to bolster staff and entered into various labor contracts with agency vendors. As a result of the pandemic and related public emergency, there was an unprecedented stress on the labor force and therefore, a high demand and dependency on agency labor. As part of management?s assessment, a competitive solicitation would have resulted in a delay and lack of required and necessary staff. As such, this specific circumstance would allow for noncompetitive procurement. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials The Corporation agrees with the finding and has developed a plan to correct the finding.

Finding Reference: 2021-001 ? Other Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing Number 93.461 COVID 19 ? HRSA COVID 19 Claims Reimbursement for the Uninsured Program Award Periods: February 4, 2020 ? Ongoing Description: Timely Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition The Corporation did not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2021 in a timely manner. Cause The Schedule for the year ended June 30, 2021 included a number of COVID 19 programs. These programs did not follow the historical grant process and therefore, various individuals in the Corporation were involved and responsible for monitoring the terms and conditions of the federal Section III ? Federal Award Findings and Questioned Costs (continued) awards and reporting of the federal expenditures. COVID 19 also impacted a number of resources within the Corporation causing various constraints. Management continued to enhance procedures related to preparation and assessment of the Schedule. However, assistance listing number 93.461 COVID 19 ? HRSA COVID 19 Claims Reimbursement for the Uninsured Program continued to cause delays, which was the primary driver in the delay of the finalization of the Schedule. Refer to finding 2021-002 for further details. Effect or potential effect The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID 19 nature of the funds. Questioned costs None. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2020-001. Context The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation The Corporation?s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of responsible officials There is no disagreement with the audit finding.

Finding Reference: 2021-002 ? Activities Allowed or Unallowed and Eligibility Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing Number 93.461 COVID 19 ? HRSA COVID 19 Claims Reimbursement for the Uninsured Program Award Periods: February 4, 2020 ? Ongoing Description: Noncompliance of HRSA Terms and Conditions Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Department of Health and Human Services (HHS) ? Health Resources Services and Administrative (HRSA) issued Terms and Conditions for Participation in the HRSA COVID 19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID 19 Uninsured Program must comply with, including the following: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2020 Consolidated Appropriations. Per the HRSA T&Cs and further clarified in the HRSA FAQs for COVID 19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration, the FAQ states the following: ?If a provider tests for COVID 19 as part of pre-operatives or other medical treatment unrelated to COVID 19, is the test eligible for reimbursement? Section III ? Federal Award Findings and Questioned Costs (continued) For the HRSA COVID 19 Uninsured Program, COVID 19 testing is eligible for reimbursement if one of the following diagnoses codes is included in any position on the claims: ? Z03.818 ? Encounter for observation for suspected exposure to other biological agents ruled out (possible exposure to COVID 19) ? Z11.59 ? Encounter for screening for other viral diseases (asymptomatic) ? Z20.828 ? Contact with and (suspected exposure to other communicable (confirmed exposure to COVID 19) ? Z11.52 ? Encounter for screening for COVID 19 (asymptomatic) ? Z20.822 ? Contact with and (suspected exposure to COVID 19 ? Z86.16 ? Personal history of COVID 19 Related treatment visits and services are not eligible for reimbursement given the primary reason for treatment is not COVID 19.? Per the HRSA T&Cs (for COVID 19 testing and testing-related items): ?FFCRA Uninsured Individuals means individuals who, as of the date of service for which Recipient seeks Payment, are not enrolled in ? ? A Federal health care program (as defined under section 1128B(f) of the Social Security Act (42 U.S.C. 1320a-7b(f), including an individual who is eligible for medical assistance only because of subsection (a)(10)(A)(ii)(XXIII) of Section 1902 of the Social Security Act; or ? A group health plan or health insurance coverage offered by a health insurance issuer in the group or individual market (as such terms are defined in section 2791 of the Public Health Service Act (42 U.S.C. 300gg-91)), or a health plan offered under chapter 89 of title 5, United States Code.? Section III ? Federal Award Findings and Questioned Costs (continued) Per the HRSA T&Cs (for COVID 19 treatment): Uninsured individuals are ?individuals who do not have any health care coverage at the time the services were provided.? Per the HRSA T&Cs (for Uninsured Program Fund Payments): ?Providers must verify and attest that to the best of the provider?s knowledge at the time of claim submission, the patient was uninsured at the time the services were provided. For claims for COVID 19 testing and testing-related items and services, treatment of positive cases of COVID 19, and/or vaccine administration, this means that the patient did not have any health care coverage. Providers may submit a claim for uninsured individuals before Medicaid eligibility determination is complete. However, if the provider learns that the individual is retroactively enrolled in Medicaid as of the date of service, the provider must return the payment to HRSA.? Condition The Corporation did not document its compliance with the HRSA COVID 19 Uninsured Program T&Cs. For certain emergency department visits that included COVID 19 testing, but COVID 19 was not the primary reason for the related treatment visit and services, the Corporation erroneously billed the HRSA COVID 19 Uninsured Program for the entire encounter, which was not in compliance with the HRSA COVID 19 Uninsured Program regulations. Refunds required to be made to HRSA COVID 19 Uninsured Program were not identified. Cause The Corporation did not have internal controls in place to formally document its compliance with the HRSA COVID 19 Uninsured Program T&Cs. The Corporation did not have internal controls in place to monitor the Program T&Cs and underlying HRSA COVID 19 Uninsured Program regulations during the COVID 19 pandemic. Section III ? Federal Award Findings and Questioned Costs (continued) The Corporation did not have internal controls in place to formally documents its compliance with the HRSA COVID 19 Uninsured Program?s allowability requirements. Outpatient encounters that included a COVID 19 testing diagnosis code, where the primary treatment diagnosis code was not COVID 19 related, were not reviewed prior to submission to HRSA to verity treatment costs were allowable under the HRSA COVID 19 Uninsured Program. The Corporation did not have suitably designed controls in place to ensure that the HRSA COVID 19 Uninsured Program is reimbursed for services provided to patients who have retroactively been approved for alternate insurance coverage. Effect or potential effect The Corporation could be in noncompliance with the HRSA COVID 19 Uninsured Program T&Cs. Certain claims submitted to the HRSA COVID 19 Uninsured Program were for unallowable activities and were, therefore, not eligible for reimbursement under the HRSA COVID 19 Uninsured Program. A patient may not be uninsured, and therefore, the related encounter may be ineligible for reimbursement under the HRSA COVID 19 Uninsured Program. Credit balances may not be resolved timely, and refunds to the HRSA COVID 19 Uninsured Program may not be identified or completed in a timely manner. Questioned costs Assistance Listing 93.461 ? Overstatement of billings and refunds related to the award period ? amounts to be returned by the Corporation (includes hospital and professional billings): $1,603,030 Identification of a repeat finding This is a repeat finding and relates to prior year finding 2020-002. Section III ? Federal Award Findings and Questioned Costs (continued) Context We sampled 60 claims (totaling $2,666,418 in federal expenditures) for services occurring during the award period that were billed to the HRSA COVID 19 Uninsured Program and noted two emergency room claims that were billed to HRSA for the treatment and testing (totaling $2,705 in federal expenditures) where COVID-19 was not the primary reason for the related treatment visit and service. In addition to the outpatient claim exceptions above, we identified two claims that were paid by HRSA but other insurance was identified on the account subsequent to HRSA claim submission (totaling $410 in federal expenditures). These claims did not subsequently bill the other insurance and HRSA had not been refunded. Management performed a full analysis over claims submitted to HRSA related to claims where COVID-19 was not the primary reason for the related treatment visit and service and where other insurance was identified subsequently during the award period. Management estimated that patient accounts totaling $1,753,156 were to be refunded to HRSA. A majority of the refunds have been returned to HRSA. The claims noted above in our sample were included in the $1,753,156 total amount to be returned to HRSA. The federal expenditures for Assistance Listing 93.461 totaled $7,519,861 for the year ended June 30, 2021. Recommendation The Corporation should implement internal controls to document its review and compliance with the HRSA COVID 19 Uninsured Program T&Cs. The Corporation should implement sufficiently precise internal controls to review changes to the HRSA COVID 19 Uninsured Program to ensure it is administering the program in compliance with the HRSA COVID 19 Uninsured Program regulations, including retroactive impacts of program requirements and allowable criteria. In addition, internal controls should be implemented to ensure claims submitted to the HRSA COVID 19 Uninsured Program meet the allowability criteria established by the HRSA COVID 19 Uninsured Program regulations before claims are submitted to HRSA for reimbursement. Section III ? Federal Award Findings and Questioned Costs (continued) Standard policies, procedures, and internal controls over the review for patient insurance coverage should be updated to address the unique aspects of the HRSA COVID 19 Uninsured Program. View of responsible officials Management agrees with this finding and performed a review of claims submitted to the HRSA COVID 19 Uninsured Program for potential payments for ineligible services and is in process of resubmitting any claims that require reprocessing due to overpayment.

Finding Reference: 2021-003 ? Activities Allowed or Unallowed, Allowable Costs/ Cost Principles and Reporting Federal Program Information Federal Agencies: Department of Health and Human Services; Awards: Assistance Listing Number 93.498 COVID 19 ? Provider Relief Fund Award Periods: Period 1 ? January 1, 2020 to June 30, 2021 Description: Review and Approval of the data in the HHS HRSA portal submission Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? The terms and conditions of the award require the recipient to submit reports as the secretary of HHS determines are needed to ensure compliance with conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Section III ? Federal Award Findings and Questioned Costs (continued) Condition The Corporation did not have appropriately designed internal controls in place over the COVID 19 Provider Relief Fund (PRF) grant awards related to the review and approval of the expenditures included in the HRSA portal submission. Cause As part of the Corporation?s internal controls related to the portal submission, Management did not retain sufficient evidence of review and approval of the reported expenditures. Effect or potential effect The expenditures included in the HRSA portal submission could be inaccurate or information reported to HRSA portal may be incomplete or inaccurate. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Context The Corporation submitted a total of 6 reports within the HRSA portal during Period 1. The total PRF payments received by the System were $199,644,439. For University of Maryland Medical System, the Corporation included $115,038,362 of expenditures within the HRSA portal submission. For the related HRSA portal submission, management did not retain documentation to support review and approval of the expenditures entered in the HRSA portal. Audit procedures identified no questioned costs as it related to expenditures included within the HRSA portal submission. Section III ? Federal Award Findings and Questioned Costs (continued) Recommendation Management should retain enhanced documentation that supports its review and approval of the reported expenditures for the HRSA portal submission to ensure that the reported amounts were in accordance with the terms and conditions. View of responsible officials Management will implement procedures to maintain evidence of management approval prior to submission.

Finding Reference: 2020-001 Federal Program Information Federal Agencies: Department of Health and Human Services; Department of Homeland Security Awards: Assistance Listing Number 93.461 COVID-19 ? HRSA COVID-19 Claims Reimbursement for the Uninsured Program; Assistance Listing Number 97.036 COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Award Periods: 2/4/2020 ? Ongoing 1/20/2020 ? 9/26/2020 Description: Timely Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? Condition The Corporation had not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2020 in a timely manner. Cause The Schedule for the year ended June 30, 2020 included a number of COVID-19 programs. These programs did not follow the historical grant process and therefore, various individuals in the Corporation were involved and responsible for the monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. COVID-19 also impacted a number of resources within the Corporation causing various constraints. Effect or potential effect The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID-19 nature of the funds. Questioned costs None. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2019-001. Context The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation The Corporation?s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding.

GSA_MIGRATION

Finding Reference: 2019-002 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance CFDA Number: 16.575 Pass-through Agency: Maryland Governor?s Office of Crime Control & Prevention Pass-through Number: VIPP-2019-0005 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR ? 200.333 Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: The Corporation did not maintain adequate documentation to support the amount charged to the grant. The division that monitors the VIPP-2019-0005 has had significant turnover in leadership. Questioned costs: $303 Context: Testing of 25 payroll transactions charged to the Crime Victim Assistance Grant noted exceptions in 2 transactions. We were unable to recalculate the total amount charged to the grant based on the payroll support provided. The 2 transactions were related to the VIPP-2019-0005 grant. Cause: During our testing we noted the Corporation did not follow their internal controls designed to ensure compliance with Allowable Cost. Effect: The amount charged to the grant could be incorrect based on missing or inaccurate information. Recommendation: We recommend management review their procedures over maintenance of records and make revisions as necessary to ensure all amounts charged to the grant are supported. Views of responsible officials: There is no disagreement with the audit finding.

Finding Reference: 2019-003 Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance CFDA Number: 16.575 Pass-through Agency: Maryland Governor?s Office of Crime Control & Prevention Pass-through Number: VIPP-2019-0005, VOCA-2018-0010, VOCA-2016-0083 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR ? 200.328 (b)(1) states The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Per the Grant Agreements, quarterly programmatic reports are due no later than 15 calendar days from the end of each quarter, and financial reports are due within 30 calendar days of each quarter end date. Condition: The Corporation did not have proper procedures in place to ensure the reporting requirements of the grantor were met. Questioned costs: None. Context: Testing of 14 quarterly reports submitted to the pass-through entity during the fiscal year noted exceptions with 4 as follows: ? 1 financial report was not submitted timely ? 3 programmatic reports were not submitted timely Cause: During our testing we noted the Corporation did not follow internal controls designed to ensure compliance with reporting requirements Effect: Lack of timely completion, review and submission of reports could result in inaccurate reporting to the pass-through entity. Recommendation: We recommend management review their procedures and make revisions as necessary to ensure quarterly reports are completed, reviewed and submitted timely to the passthrough entity. Views of responsible officials: There is no disagreement with the audit finding.

GSA_MIGRATION