CITY OF GREELEY, COLORADO

Assistance Listing Number, Federal Agency, and Program Name - ALN 15.916, Department of the Interior, Outdoor Recreation Acquisition, Development and Planning, Outdoor Recreation Acquisition, Development and Planning Grants, and ALN 66.468, Environmental Protection Agency, Drinking Water State Revolving Fund. Federal Award Identification Number and Year - All grants under ALN Pass through Entity - ALN 15.916, Colorado Department of Natural Resources, and ALN 66.468, Colorado Water Resources and Power Development Authority Finding Type - Material weakness Repeat Finding - Yes 2024 002 Criteria - Per 2 CFR Section 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended determined in accordance with Section 200.502. Condition - The Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - The Outdoor Recreation Acquisition, Development and Planning program expenditures of $1,250,000 were omitted. The Drinking Water State Revolving Fund program was overstated by $76,884. The final SEFA has been corrected. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate, and, as a result, the SEFA was adjusted for two federal programs. This did impact major program determination for Outdoor Recreation Acquisition, Development and Planning. Recommendation - We recommend the City ensure the effectiveness of controls to ensure expenditures reported on the SEFA are complete and accurate. Views of Responsible Officials and Corrective Action Plan - The Finance Department recently hired a new Grants Manager after being without this critical position for almost a year. The Grants Manager, along with the Grant Specialist and the Financial Reporting team accountants, plan to work together to improve the tracking and reconciliation of grant activity. In addition, the City implemented eCivis Euna Grants, a grant application, tracking, and reporting system, in November of 2025. The Grants Team will be working with Departments to document the grants process formally for the City and this will ensure that all grants are accounted for and tracked in the Euna grants system. This renewed capacity and new initiatives, supported by the new administrative cost recovery framework and the City's grants management platform, reflects a broader commitment to managing external funding with the same discipline applied to locally generated revenues.

Assistance Listing, Federal Agency, and Program Name ALN 14.218, U.S. Department of Housing and Urban Development, Entitlement Grants Cluster (CDBG), Community Development Block Grants/Entitlement Grants and ALN 20.507, U.S. Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Federal Award Identification Number and Year All grants under ALN Pass through Entity N/A Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR Section 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended determined in accordance with Section 200.502. Condition The CDBG Cluster and Federal Transit Cluster expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Questioned Costs None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported Not applicable Identification of How Questioned Costs Were Computed Not applicable Context The CDBG Cluster expenditures were overstated by $792,426 and the Federal Transit Cluster expenditures were overstated by $365,634. The final SEFA has been corrected. Cause and Effect Controls in place did not ensure the SEFA was complete and accurate and as a result, the SEFA needed to be adjusted for two federal clusters. This did not impact major program determination. Recommendation The City should implement a process to ensure the expenditures reported on the SEFA are complete and accurate. Views of Responsible Officials and Corrective Action Plan Due to turnover and the loss of a long term employee new processes were implemented to prepare reporting and documentation processes for the Federal Transit Cluster. Written Standard Operating Procedures have been generated and will be updated as necessary. Reporting and draw processes have been updated to include written signatures of approval for the documentation. The staff in transit and finance work closely together to ensure the completeness of records. City of Greeley will also be organizing a formalized grants team that will be dedicated to all grant activities including the SEFA and correcting the prior staffing insufficiencies.

Assistance Listing, Federal Agency, and Program Name - 15.507, WaterSMART Sustaining and Manage America’s Resources for Tomorrow Federal Award Identification Number and Year - R22AP00523-00 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a non-federal entity must 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). Condition - Controls in place were not adequate to ensure expenses were reported in the proper categories on the performance reports. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During reporting testing, we noted no expenses were reported in the federal expenses line item of the two reports tested. Cause and Effect - While the City did have controls in place around reporting and allowability of expenses, they were not sufficient to ensure expenses were properly reported on the correct lines As a result, reports were not in compliance. Recommendation - We recommend the City ensure the effectiveness of controls to ensure expenditures get reported properly. Views of Responsible Officials and Corrective Action Plan - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.

Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126 Pass-through Entity - Colorado Department of Local Affairs Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person. Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs. Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors. Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search. Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.

Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126 Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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). Condition - There was no evidence that reports were reviewed for completeness and accuracy prior to submission. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission. Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission. Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission. Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.