Wireless Infrastructure Association and AffiliatesNon-Profit

Criteria In accordance with 2 CFR 200.305(b), entities receiving federal funds are responsible for ensuring payment methods minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Condition and Context The Organization engaged the services of an information technology firm for the initial development work (Phase 1) to create a tool to assist in outreach to employers in Ohio that are in the broadband sector. This initial development work was completed in September 2023 at a cost of $100,000. The Organization requested reimbursement of this expense in November 2023 as part of the award’s final close-out procedures. Given that the Organization was negotiating terms with this vendor for Phase 2 of this effort, the Organization did not issue a payment to the vendor for the $100,000 that had been received. Rather, the Organization determined it would be appropriate to withhold payment to the vendor until the Phase 2 negotiations were completed or terminated. Cause The ongoing work related to this project was to be completed under a different federal contract. Thus, the Organization determined that it would be in the best interest of the overall project to hold payment for the completed Phase 1 work until a comprehensive agreement for Phase 2 could be reached. The vendor was amenable to this arrangement. The contract negotiations have taken longer than anticipated. As a result, payment has been delayed. Effect The Organization’s treatment of this $100,000 reimbursement was not in compliance with the requirements of the cash management provisions of 2 CFR 200.305(b). Repeat Finding No. Recommendation We recommend that the Organization review its processes to ensure all reimbursements of federal funds are remitted in a timely manner to vendors. Views of Responsible Officials and Planned Corrective Actions See attached corrective action plan. Questioned Costs None.

Finding 2020-001: Procurement, Suspension and Debarment Federal agency: U.S. Department of Labor Program: Research and Development Cluster Assistance listing number: Various Criteria: 2 CFR 200.318 states non-federal entities must have and use documented procurement procedures that conform to 2 CFR 200.317 through 200.327. 2 CFR 200.214 states non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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. 2 CFR 200 requires adequate documentation of compliance with 2 CFR 200.214. Condition: The Association established a documented procurement policy. The procurement policy requires enhancements to fully comply with the requirements of 2 CFR 200.317 through 200.327. The Association established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The procurement policy did not identify which individuals were responsible for completing and retaining documentation of suspension and debarment checks. We noted as part of our testing that there was no documentation that these policies and procedures were being followed. Cause: The Association?s procurement policy did not confirm to 2 CFR 200.317 through 200.327 and management did not document compliance with the above criteria regarding suspension and debarment. Effect: The Association?s procurement policy did not conform 2 CFR 200.317 through 200.327. The Association?s documentation was lacking evidence of tracking vendors for suspension and debarment. Questioned costs: None Repeat finding: No Recommendation: We recommend management develop written updates to the procurement policy to conform to 2 CFR 200.317 through 200.327. We recommend that the Association add and monitor the formal procedure and policy with a designated individual(s) responsible to ensure documentation is retained satisfying the compliance requirement detailed above. Views of responsible officials: See corrective action plan.