Metropolitan Park District of the Toledo AreaLocal Government

2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by Office of Management and Budget (OMB), the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted two out of four (50%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2024. Failure to properly submit quarterly reports could result in USODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to USODOT, to help ensure the reports are complete and accurate.

2 CFR § 1400.332 requires participants to include a term or condition in lower-tier transactions requiring lower-tier participants to comply with Subpart C of the OMB Guidance in 2 CFR Part 180. 2 CFR Part 180, Subpart C, Paragraph 300 instructs, "when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, in 31 CFR § 19.300, the U.S. Department of Treasury requires participants entering into a covered transaction with another person at the next lower tier, to verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, District Policy: Federal Procurement System Standards – Debarment and Suspension, Procurement, states that for contracts over $25,000, the District shall confirm that the vendor is not debarred or suspended by either checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the vendor; or adding a clause or condition to the covered transaction with that vendor. The District did not have the proper internal controls in place to verify that all entities, with whom the District had entered into covered transactions, had not been suspended or debarred. During testing of Outdoor Recreation Acquisition, Development, and Planning and Coronavirus State and Local Fiscal Recovery Funds, we noted in each program the District entered into a contract with a vendor for more than $25,000 and, there was no evidence the District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verifications were not completed for the two awarded contracts during Fiscal Year 2023. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

2 CFR § 1400.332 requires participants to include a term or condition in lower-tier transactions requiring lower-tier participants to comply with Subpart C of the OMB Guidance in 2 CFR Part 180. 2 CFR Part 180, Subpart C, Paragraph 300 instructs, "when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, in 31 CFR § 19.300, the U.S. Department of Treasury requires participants entering into a covered transaction with another person at the next lower tier, to verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, District Policy: Federal Procurement System Standards – Debarment and Suspension, Procurement, states that for contracts over $25,000, the District shall confirm that the vendor is not debarred or suspended by either checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the vendor; or adding a clause or condition to the covered transaction with that vendor. The District did not have the proper internal controls in place to verify that all entities, with whom the District had entered into covered transactions, had not been suspended or debarred. During testing of Outdoor Recreation Acquisition, Development, and Planning and Coronavirus State and Local Fiscal Recovery Funds, we noted in each program the District entered into a contract with a vendor for more than $25,000 and, there was no evidence the District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verifications were not completed for the two awarded contracts during Fiscal Year 2023. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.

2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.

2 CFR § 1400.332 requires participants to include a term or condition in lower-tier transactions requiring lower-tier participants to comply with Subpart C of the OMB Guidance in 2 CFR Part 180. 2 CFR Part 180, Subpart C, Paragraph 300 instructs, "when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, in 31 CFR § 19.300, the U.S. Department of Treasury requires participants entering into a covered transaction with another person at the next lower tier, to verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, District Policy: Federal Procurement System Standards – Debarment and Suspension, Procurement, states that for contracts over $25,000, the District shall confirm that the vendor is not debarred or suspended by either checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the vendor; or adding a clause or condition to the covered transaction with that vendor. The District did not have the proper internal controls in place to verify that all entities, with whom the District had entered into covered transactions, had not been suspended or debarred. During testing of Outdoor Recreation Acquisition, Development, and Planning and Coronavirus State and Local Fiscal Recovery Funds, we noted in each program the District entered into a contract with a vendor for more than $25,000 and, there was no evidence the District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verifications were not completed for the two awarded contracts during Fiscal Year 2023. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

2 CFR § 1400.332 requires participants to include a term or condition in lower-tier transactions requiring lower-tier participants to comply with Subpart C of the OMB Guidance in 2 CFR Part 180. 2 CFR Part 180, Subpart C, Paragraph 300 instructs, "when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, in 31 CFR § 19.300, the U.S. Department of Treasury requires participants entering into a covered transaction with another person at the next lower tier, to verify that the person with whom they intend to do business is not excluded or disqualified by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person. Additionally, District Policy: Federal Procurement System Standards – Debarment and Suspension, Procurement, states that for contracts over $25,000, the District shall confirm that the vendor is not debarred or suspended by either checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the vendor; or adding a clause or condition to the covered transaction with that vendor. The District did not have the proper internal controls in place to verify that all entities, with whom the District had entered into covered transactions, had not been suspended or debarred. During testing of Outdoor Recreation Acquisition, Development, and Planning and Coronavirus State and Local Fiscal Recovery Funds, we noted in each program the District entered into a contract with a vendor for more than $25,000 and, there was no evidence the District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verifications were not completed for the two awarded contracts during Fiscal Year 2023. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.

2 CFR § 1201.1 except as otherwise provided in this part, the Department of Transportation adopts the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). 2 CFR § 200.328 states unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead). This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. The District’s grant agreement states on or before the 20th day of the first month of each quarter and until the budget period end date of December 31, 2026, the Recipient shall submit to the U.S. Department of Transportation (USDOT) a Quarterly Project Progress Report and Recertification. During testing we noted four out of four (100%) of the District’s quarterly reports were submitted to USDOT with the incorrect expenditures, report period or grant period. Due to the deficient internal control structure, elements of the reporting requirements were not properly submitted during Fiscal Year 2023. Failure to properly submit quarterly reports could result in ODOT taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to ODOT, to help ensure the reports are complete and accurate.

2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the ALN number or other identifying number when the ALN information is not available. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The District’s internal control procedures did not identify $1,943,931 of expenses in the Schedule of Expenditures of Federal Awards related to the Highway Planning and Construction funds. Adjustments, to which management have agreed, are reflected in the accompanying Schedule. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit.

2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the District’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the ALN number or other identifying number when the ALN information is not available. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The District’s internal control procedures did not identify $1,943,931 of expenses in the Schedule of Expenditures of Federal Awards related to the Highway Planning and Construction funds. Adjustments, to which management have agreed, are reflected in the accompanying Schedule. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit.

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