THE NATIONAL RHCA TRAINING AND SAFETY FOUNDATION

Finding 2024‐001: Reporting – significant deficiency in internal control over compliance and compliance finding. Criteria: Grantees who are subject to single audit requirements are required to submit their Data Collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors’ report or 9 months after the audit period. Condition: The Foundation’s Data Collection form was late for the year ended December 31, 2024. Cause: Delays in completing the audit resulted in the Data Collection form being submitted after 9 months from the end of the audit period. Effect: The Foundation was not in compliance with single audit reporting requirements. Questioned Costs: None Recommendation: Internal controls and processes should be implemented to ensure audits are completed in a timely manner to meet federal reporting deadlines. Management’s response: See corrective action plan.

Finding 2024‐002: Allowable costs and activities – material weakness in internal control over compliance and compliance finding. Criteria: The Uniform Guidance requires subrecipients to maintain adequate documentation to support costs charged to the federal award. For costs to be allowable under federal awards, costs must be adequately documented. Condition: The Foundation did not maintain sufficient documentation to support payroll expenses allocated to the federal grant. It was difficult to determine how the payroll costs were being allocated. Cause: The Foundation often charged their funder based on gross pay rates. The funder would subsequently work with the Foundation to properly allocate payroll costs based on grant requirements. However, the Foundation did not maintain documentation to support the ultimate amount allocated and paid by the grant. Effect: The Foundation was not in compliance with federal requirements related to maintaining adequate documentation to support all expenses charged to federal grants. Questioned Costs: None Recommendation: The Foundation should implement internal control procedures that ensure amounts reimbursed by federal grants are fully supported by detailed supporting documentation.

Finding 2024‐003: Procurement – material weakness in internal control over compliance and compliance finding. Criteria: Under the Uniform Guidance, formal procurement methods are required when the value of the procurement transaction under a Federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Formal procurement methods are competitive and require public notice. Condition: The Foundation did not adhere to federal procurement requirements when entering into a construction contract during the year. Cause: The procurement process and project award associated with this project originally occurred in 2019, including project planning, cost analysis, contractor evaluation, procurement activities, and a groundbreaking ceremony prior to the COVID‐19 pandemic. Due to COVID‐19‐ related delays and impacts, the commencement of construction activities was significantly postponed, resulting in the need for a new contract in 2024 for remaining work.Effect: The Foundation was not in compliance with federal procurement requirements for the new contract signed in 2024. Questioned Costs: None Recommendation: The Foundation should implement an internal control process that ensures federal procurement requirements are followed for all applicable purchases. Management’s response: See corrective action plan.

Finding 2024‐004: Suspension and debarment – significant deficiency in internal control over compliance Criteria: Regulations in 2 CFR Part 180 restrict subrecipients from entering into contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: The Foundation did not maintain documentation to support their determination that a contractor was not suspended or debarred before entering into a contract. Cause: Inexperience with federal awards resulted in document retention failures. Effect: The Foundation’s internal controls over suspension and debarment compliance were not properly designed and implemented to reduce the risk of noncompliance with federal requirements. The contractor was not suspended or debarred by the federal government. Questioned Costs: None Recommendation: The Foundation should implement internal control processes to ensure all contractors paid with federal funds are searched on SAM.gov to ensure they are not suspended or debarred before the contract is finalized. Dated documentation should be retained to support that the search was completed before the contract was signed. Management’s response: See corrective action plan.