CITY OF ESPANOLA

2024‐004 (2022‐009) Single Audit Report Submission (Other Non‐compliance) (Repeat/Modified) Federal program information: Funding agency: All Programs Title: All Programs Federal Assistance Listing Number: All Programs Compliance Requirement Reporting Award Period: July 1, 2023 to June 30, 2024 Condition: The City’s fiscal year ended June 30, 2024, single audit reporting package was not submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period. The City did not make progress on this finding in 2024. Criteria: 2 CFR Section 200.50(c) of the Uniform Guidance requires that the Single Audit reporting package be submitted within nine months after the end of the audit period. Effect: The City is not in compliance with reporting requirements of the Uniform Guidance. Questioned Costs: None Cause: The City experienced significant turnover during this fiscal year, and it resulted in both operations and closing of the previous fiscal year to be delayed which made everything late. Auditors’ Recommendation: We recommend that the City should work to catch up the closing process in order to ensure that the next year’s audit is performed timely in order for the next year’s audit reporting package to be submitted by the federal clearing house due date. Agency’s Response: The City is working to get current with the accounting processes and financials that would enable the timely performance of the annual financial audit. The Finance Director has contracted a public accounting firm for assistance to accelerate this process and ensure future timely audit completion. In addition, the Finance Department has implemented multiple monthly and annual reconciliation processes to ensure the general ledger is completed timely and accurately. Training of City staff on completion of monthly processes is ongoing and will continue with oversight by the Finance Director. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

2024‐005 Reporting (2023‐009) Reporting (Significant Deficiency) (Repeat/Modified) Federal Program Information: Funding Agency: Department of the Justice Title: Public Safety Partnership and Community Policing Grants Assistance Listing Number: 16.710 Compliance Requirement: Reporting Award Year: July 1, 2023 to June 30, 2024 Condition: During our audit, we noted that the City did not submit all of its quarterly financial reports and one progress report in a timely manner. The City did make progress in this finding. In prior year, the City did not submit the proper reports, however, this year, all 4 quarterly reports were submitted, however, 3 out of 4 were late. Criteria: The City must submit the federal financial reports 30 days after the end of the end of each quarter (2 CFR 200.329 section (c)(1). Effect: The City was not in compliance with the reporting requirement; the City did not submit information in a timely manner for three quarters of the fiscal year. Questioned Costs: None Cause: The City had turnover that handled this duty during the time that the reports were due to be submitted and so it was not completed until the end of the fiscal year. Auditors’ Recommendation: We recommend that the City ensure that it has more than one position responsible for submitting these quarterly and any progress reports to the federal government to ensure that they are always completed even if one position is vacant. Agency’s Response: The City of acknowledges the audit finding regarding the untimely submission of reporting for the Cops Hiring program. This was a result of turnover, and the new grant manager was not hired until the middle of fiscal year 2024. The Procurement officer, who manages grants, as well as the Finance Director, have prioritized compliance with federal reporting requirements. To prevent future occurrences, the Finance Department has implemented internal controls ensuring multiple staff members are responsible for federal reporting. Specifically, both the Finance Director and the Financial Analyst now share the responsibility and authority to complete and submit these annual reports. This new process ensures continuity in reporting, even in the event of staff turnover, and strengthens the City’s commitment to compliance with federal funding requirements. Additionally, the Finance Director oversees this responsibility so there are now multiple controls to ensure timely completion. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

Federal program information: Funding agency: All Programs included in SEFA Title: All Programs included in SEFA Federal Assistance Listing Number: All Programs included in SEFA Compliance Requirement Reporting Award Period: July 1, 2022 to June 30, 2023 Condition: During our procedures over the Schedule of Expenditures of Federal Awards we noted the City did not accurately complete a Schedule of Expenditures and Federal Awards for audit purposes in a timely manner. The City did not made progress in this area during fiscal year 2023. However, in fiscal year 2025, the City was able to complete an accurate Schedule of Expenditures of Federal Awars for fiscal year 2023. Criteria: OMB Uniform Guidance section 200.508 (b) requires auditees in to prepare the schedule of federal awards in accordance with OMB Uniform Guidance section200.510. Cause: The City had a large turnover in the finance area and was not required to create a Schedule of Federal Awards in prior years as they have just recently started receiving federal funding and so they were not familiar with the process. Effect: The City is in violation of the Uniform Guidance requirements. Auditor’s Recommendation: We recommend that the City implement a system to ensure the preparation of the Schedule of Expenditure and Federal Awards be done in the closing process so that when the audit starts the Schedule of Expenditure and Federal Awards is ready to be audited and is complete. Agency’s Response: The City did complete the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023 (fiscal year 2023) and was not completed timely as a result of staff turnover during fiscal year 2023. The schedule was completed, and no modifications were noted as a result of audit procedures to the completeness and accuracy of the SEFA. The City’s Procurement officer now maintains responsibility for grants from award to reversion date. A tracking file has been created and is maintained for all active grants at the point of award, expenditure, reimbursement, and close out. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

Federal program information: Funding agency: All Programs included in SEFA Title: All Programs included in SEFA Federal Assistance Listing Number: All Programs included in SEFA Compliance Requirement Reporting Award Period: July 1, 2022 to June 30, 2023 Condition: The City’s fiscal year ended June 30, 2023, single audit reporting package was not submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period. The City has not made progress in this area during 2023 fiscal year. Criteria: 2 CFR Section 200.50(c) of the Uniform Guidance requires that the Single Audit reporting package be submitted within nine months after the end of the audit period. Effect: The City is not in compliance with reporting requirements of the Uniform Guidance. Questioned Costs: None Cause: The City experienced significant turnover during this fiscal year, and it resulted in both operations and closing of the previous fiscal year to be delayed which made everything late. Auditors’ Recommendation: We recommend that the City should work to catch up the closing process in order to ensure that the next year’s audit is performed timely in order for the next year’s audit reporting package to be submitted by the federal clearing house due date. Agency’s Response: The City is working to get current with the accounting processes and financials that would enable the timely performance of the annual financial audit. The Finance Director has contracted a public accounting firm for assistance to accelerate this process and ensure future timely audit completion. In addition, the Finance Department has implemented multiple monthly and annual reconciliation processes to ensure the general ledger is completely accurately and timely. Training of City staff on completion of monthly processes is ongoing and will continue with oversight by the Finance Director. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

Federal Program Information: Funding Agency: Department of the Treasury Title: Coronavirus State and Local Fiscal Recovery Fund Program Assistance Listing Number: 21.027 Compliance Requirement: Reporting Award Year: July 1, 2022 to June 30, 2023 Condition: During our audit, we noted that the Project and Expenditures Report was not submitted to the Department of the Treasury in a timely manner. Criteria: The City must fill out and submit the Project and Expenditures Report by April 30 of each fiscal year that they receive Coronavirus State and Local Fiscal Recovery Funds (2 CFR 200.328 & 31 CFR section35.4(c)). Effect: The City did not submit its required annual report for the fiscal year 2023. Questioned Costs: None Cause: The City had turnover in its upper management that handled this duty during the time that the report was due to be submitted and so it was never completed. Auditors’ Recommendation: We recommend that the City ensure that it has more than one position responsible for submitting these annual reports to the federal government to ensure that they are always completed even if one position is vacant. Agency’s Response: The City of acknowledges the audit finding regarding the untimely submission of the Project Expenditure Report for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. The report for fiscal year 2023 was not submitted due to turnover in upper management and the grants manager position, resulting in the report being neither completed nor submitted during that time. Since taking office in fiscal year 2024, the current Finance Director has prioritized compliance with federal reporting requirements. As of fiscal year 2025, all required project and expenditures reporting has been completed and submitted in accordance with U.S. Department of Treasury guidelines. To prevent future occurrences, the Finance Department has implemented internal controls ensuring multiple staff members are responsible for federal reporting. Specifically, both the Finance Director and the Financial Analyst now share the responsibility and authority to complete and submit these annual reports. This new process ensures continuity in reporting, even in the event of staff turnover, and strengthens the City’s commitment to compliance with federal funding requirements. In addition, The City’s Procurement officer now maintains responsibility for grants from award to reversion date. A tracking file is maintained for all active grants at the point it is awarded, expended, and reimbursement received to ensure this process is properly managed. Additionally, the Finance Director oversees this responsibility so there are now multiple controls to ensure timely completion. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

Federal Program Information: Funding Agency: Department of the Treasury Title: Coronavirus State and Local Fiscal Recovery Fund Program Assistance Listing Number: 21.027 Compliance Requirement: Procurement Award Year: July 1, 2022 to June 30, 2023 Condition: During our testing of compliance over the Procurement requirements we noted the following:  From review of 2 of the vendors paid with the Coronavirus State and Local Fiscal Recovery Fund Program that were paid over $60,000 during the year, there was no evidence that the City went through the proper required procurement process to select the vendors. Criteria: Per 2 CFR sections 200.318 through 200.327, all procurement functions, including but not limited to preparation of specifications, solicitation of sources, qualification or disqualification of sources, preparation and award of contract and contract administration must be done for the vendors used for the federal expenditures based off the City’s procurement policies and procedures. Effect: The City violated its established procurement code and may not have obtained the best price for the goods and services received during the year for the Coronavirus State and Local Fiscal Recovery Fund Program. Cause: There was management override and lack of proper training in CPO and accounts payable positions, and therefore, the process was not properly followed during the fiscal year. Auditors’ Recommendations: We recommend the City implement policies and procedures as soon as possible to ensure compliance with procurement requirements pertain to each procurement that occurs during the fiscal year and no payments are made through direct voucher. Agency’s Response: Since taking office in fiscal year 2024, the current Finance Director has implemented a Standard Operating Procedure (SOP) in alignment with the Procurement Policy adopted in 2022 to ensure compliance with the State Procurement Code, internal controls, and the proper segregation of duties in procurement. This SOP outlines the specific roles and responsibilities of the Certified Procurement Officer (CPO), Finance Director, City Manager, and City Council when applicable in the procurement process. In addition, a procurement workflow has been created to be utilized by the (CPO) to ensure compliance with the City of Espanola’s procurement policy, the State Procurement Code, and appropriate checks and balances at varying thresholds. The (CPO) is responsible for ensuring all policies and state procurement laws are followed throughout the process. Additionally, all documentation from initiation to the issuance of a Purchase Order (PO) is retained electronically in a complete packet for record-keeping and audit purposes. In order to address direct payment voucher controls, the City has restricted the use of direct payment vouchers for high-volume purchases. All procurements must follow the purchase order process, unless an exception is authorized in accordance with policy. The finance department has also implemented issuing procurement violations to any department head or staff who authorizes a purchase in the absence of an approved purchase order, which aligns with the 2022 Adopted Procurement Policy. By enforcing these measures, the City ensures procurement policy compliance, transparency, and financial accountability, thereby addressing the audit findings and preventing future violations. Responsible Parties: The Director of Finance. Timeline: June 30, 2025

Federal Program Information: Funding Agency: Department of the Treasury Title: Coronavirus State and Local Fiscal Recovery Fund Program Assistance Listing Number: 21.027 Compliance Requirement: Allowable Activities/Allowable Costs Award Year: July 1, 2021 to June 30, 2022 Condition: During our audit, we noted that the following circumstances in our testwork over disbursements for the Coronavirus State and Local Fiscal Recovery Fund program:  During our examination of disbursements, there were three transactions totaling $18,287 that the City had no supporting documentation to substantiate that the transactions had gone through the proper internal controls of the City and were allowable activities and were for allowable costs.  During our examination of disbursements, there were three transactions for $12,958 where the City did not go through the City’s internal control process for disbursements of having purchase requisitions created and approved prior to the creation of approved purchase orders. These transactions went through a direct pay voucher without having the proper approvals, which is not in compliance with the City’s approved policies and procedures over disbursements. Criteria: The City must establish internal controls over compliance with allowable activities, allowable costs (2 CFR 200.303). Effect: The City did not follow its properly designed internal control system to ensure expenditures complied with the allowable activities/allowable costs requirements for the Coronavirus State and Local Fiscal Recovery Fund program. Questioned Costs: $18,287 Cause: The City did not follow its system of internal control for some of its purchases and there were some transactions that the City could not locate because they were not properly filed. Auditors’ Recommendation: We recommend that the City ensure that it follows its internal controls for all transactions to ensure proper review of all costs associated with the Coronavirus State and Local Fiscal Recovery Fund expenditures. Agency’s Response: The Finance Department will immediately implement processes and procedures for grant requirements to ensure:  Staff follow processes and procedures  Implement controls for expending the funds  Retain proper documentation for processing reimbursements  Maintain those documents for future audit The responsible party for this finding is the finance director.

Federal program information: Funding agency: All Programs Title: All Programs Federal Assistance Listing Number: All Programs Compliance Requirement Reporting Award Period: July 1, 2021 to June 30, 2022 Condition: During our procedures over the Schedule of Expenditures of Federal Awards we noted the City did not accurately complete a Schedule of Expenditures and Federal Awards for audit purposes. The Schedule of Expenditures and Federal Awards did not indicate if the programs were directly funded or if they were passed through by another entity. Criteria: OMB Uniform Guidance requires award identification to include, as applicable, the Federal Assistance Number and title, the award number and years, the name of the federal agency, and the name of any applicable pass-through entities. Cause: The City hasn’t had to create a Schedule of Federal Awards in prior years as they have just recently started receiving federal funding and so they were not familiar with the process. Effect: The City is in violation of the Uniform Guidance requirements. Auditor’s Recommendation: We recommend that the City implement a system to ensure the City to implement systems that ensures items needed to prepare the Schedule of Expenditure and Federal Awards be done in the closing process so that when the audit starts the Schedule of Expenditure and Federal Awards is ready to be audited and is complete. Agency’s Response: The City is currently in the process of hiring additional finance staff to address the grant(s) requests for reimbursements and collecting the necessary information for the preparation of the Schedule of Expenditures of Federal Awards. The corrective action plan for this will be implemented by year end 0224. The responsible party for this finding is the finance director.

Federal program information: Funding agency: All Programs Title: All Programs Federal Assistance Listing Number: All Programs Compliance Requirement Reporting Award Period: July 1, 2021 to June 30, 2022 Condition: The City’s fiscal year ended June 30, 2022, single audit reporting package was not submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period as required by 2 CFR Section 200.50(c). Criteria: The Uniform Guidance requires that the Single Audit reporting package be submitted within nine months after the end of the audit period. Effect: The City is not in compliance with reporting requirements of the Uniform Guidance. Questioned Costs: None Cause: The City experienced significant turnover during this fiscal year, and it resulted in both operations and closing of the previous fiscal year to be delayed which made everything late. Auditors’ Recommendation: We recommend that the City should work to catch up the closing process in order to ensure that the next year’s audit is performed timely in order for the next year’s audit reporting package to be submitted by the federal clearing house due date. Agency’s Response: The City is immediately working to get current with the accounting processes that would enable the timely performance of the annual financial audit. The City is in the process of hiring more finance staff to ensure accounting data is captured accurately and timely. The corrective action plan will be implemented by year end 2024. The responsible party for this finding is the finance director. 151

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