WEST KENTUCKY RURAL TELEPHONE COOPERATIVE CORP INC

Finding: Documented Policies and Procedures related to Suspension and Debarment Program: Coronavirus Capital Projects Fund ALN Number: 21.029 Sponsoring Agency: Illinois Department of Commerce and Economic Opportunity, Tennessee Department of Economic and Community Development Pass-Through Entity Identifying Number: 2681-48014, 33023-43124 Award Period: 1/1/2024 – 12/31/2025, 6/1/2024 – 10/31/2026 Criteria or Specific Requirement: Per 2 CFR 180, all nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are not suspended or debarred. The Company must verify that the contracted entity is not suspended or debarred or otherwise excluded from participating in the transaction. The verification can be accomplished by: 1. Checking the Excluded Parties List using the SAM.GOV website. 2. Collecting a certification from the entity. 3. Adding a clause or condition to the covered transaction with the entity. If checking of the SAM.GOV website is used, the Company should perform this review timely and any time a contract includes provisions for renewal. Condition: The Company did not perform the proper checks to comply with debarment and suspension requirements. Cause: The Company did not have documented suspension and debarment procedures in place for all vendors. Effect or Potential Effect: The Company may have done business with an entity that was suspended or debarred. Questioned Costs: None Context: During testing of Suspension and Debarment and inquiry with management, it was determined that the Company does not perform the requisite suspension and debarment check on all of their vendors. Identification as a Repeat Finding: N/A Recommendation: We recommend the Company amend the formal policy to be in compliance with debarment and suspension requirements and ensure vendors are properly checked. Views of Responsible Officials and Planned Corrective Actions: The Company understands. See separate auditee documentation for planned corrective action.

Corrective Action Plan WK&T respectfully submits the following corrective action plan for the year ended December 31, 2025. Finding: 2025-001 –Suspension and Debarment Responsible Individuals: Bhavini Sokhey, Chief Financial Officer Anticipated Completion Date: Implemented Finding Summary: Lack of documented policies and procedures related to suspension and debarment Corrective Action Plan: •The Company has developed and implemented formal written policies and procedures to addresscompliance with federal suspension and debarment requirements. •Prior to awarding any contract funded with federal or state funds, the Company will verify that thevendor or contractor is not suspended or debarred by reviewing the SAM.gov Exclusions database.Documentation of the verification will be retained in the procurement file. •The Company will require all contractors participating in federally or state-funded projects toexecute a certification confirming they are not debarred, suspended, proposed for debarment,declared ineligible, or voluntarily excluded from participation in such programs. •The procurement and grant administration staff are responsible for performing and documentingthese procedures. Compliance will be reviewed as part of the Company's procurement process andongoing grant oversight to ensure adherence to federal and state requirements.