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Single Audit Report, 2024-25

County Auditors · san-luis-obispo-2024-single-audit-report-2024-25 · Single audit · 2024-01-01 · San Luis Obispo

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COUNTY OF SAN LUIS OBISPO SINGLE AUDIT REPORT YEAR ENDED JUNE 30, 2025 Page 1 of 18 COUNTY OF SAN LUIS OBISPO TABLE OF CONTENTS YEAR ENDED JUNE 30, 2025 INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS 1 INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM, REPORT ON INTERNAL CONTROL OVER COMPLIANCE, AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE 3 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 6 NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 12 SUMMARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS 14 Page 2 of 18 CliftonLarsonAllen LLP CLAconnect.com INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS Board of Supervisors County of San Luis Obispo San Luis Obispo, California We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of the governmental activities, the business-type activities, the discretely presented component unit, each major fund, and the aggregate remaining fund information of County of San Luis Obispo, as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the County of San Luis Obispo’s basic financial statements, and have issued our report thereon dated December 29, 2025. Our report includes references to other auditors who audited the financial statements of the San Luis Obispo County Pension Trust (SLOCPT), a pension trust, and First 5 San Luis Obispo, a discretely presented component unit, as described in our report on the County’s financial statements. This report does not include the results of other auditors’ testing of internal controls over financial reporting or compliance and other matters that are reported on separately by those auditors. Report on Internal Control Over Financial Reporting In planning and performing our audit of the financial statements, we considered County of San Luis Obispo’s internal control over financial reporting (internal control) as a basis for designing audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of County of San Luis Obispo’s internal control. Accordingly, we do not express an opinion on the effectiveness of County of San Luis Obispo’s internal control. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance. Our consideration of internal control was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that were not identified. CLA (CliftonLarsonAllen LLP) is an independent network member of CLA Global. See CLAglobal.com/disclaimer. (1) Page 3 of 18 Board of Supervisors County of San Luis Obispo We identified a certain deficiency in internal control, described in the accompanying schedule of findings and questioned costs as item 2025-001 that we consider to be a material weakness. Report on Compliance and Other Matters As part of obtaining reasonable assurance about whether County of San Luis Obispo’s financial statements are free from material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the financial statements. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. County of San Luis Obispo’s Response to Findings Government Auditing Standards requires the auditor to perform limited procedures on the County of San Luis Obispo’s response to the findings identified in our audit and described in the accompanying schedule of findings and questioned costs. County of San Luis Obispo’s response was not subjected to the other auditing procedures applied in the audit of the financial statements and, accordingly, we express no opinion on the response. Purpose of this Report The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the entity’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose. CliftonLarsonAllen LLP Roseville, California December 29, 2025 (2) Page 4 of 18 CliftonLarsonAllen LLP CLAconnect.com INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE FOR EACH MAJOR FEDERAL PROGRAM, REPORT ON INTERNAL CONTROL OVER COMPLIANCE, AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE Board of Supervisors County of San Luis Obispo San Luis Obispo, California Report on Compliance for Each Major Federal Program Opinion on Each Major Federal Program We have audited the County of San Luis Obispo’s (the County) compliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement that could have a direct and material effect on each of the County’s major federal programs for the year ended June 30, 2025. The County’s major federal programs are identified in the summary of auditors’ results section of the accompanying schedule of findings and questioned costs. In our opinion, the County complied, in all material respects, with the compliance requirements referred to above that could have a direct and material effect on each of its major federal programs for the year ended June 30, 2025. Basis for Opinion on Each Major Federal Program We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America (GAAS); the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States; and the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Our responsibilities under those standards and the Uniform Guidance are further described in the Auditors’ Responsibilities for the Audit of Compliance section of our report. We are required to be independent of County of San Luis Obispo and to meet our other ethical responsibilities, in accordance with relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on compliance for each major federal program. Our audit does not provide a legal determination of the County’s compliance with the compliance requirements referred to above. Responsibilities of Management for Compliance Management is responsible for compliance with the requirements referred to above and for the design, implementation, and maintenance of effective internal control over compliance with the requirements of laws, statutes, regulations, rules, and provisions of contracts or grant agreements applicable to the County’s federal programs. CLA (CliftonLarsonAllen LLP) is an independent network member of CLA Global. See CLAglobal.com/disclaimer. (3) Page 5 of 18 Board of Supervisors County of San Luis Obispo Auditors’ Responsibilities for the Audit of Compliance Our objectives are to obtain reasonable assurance about whether material noncompliance with the compliance requirements referred to above occurred, whether due to fraud or error, and express an opinion on the County’s compliance based on our audit. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS, Government Auditing Standards, and the Uniform Guidance will always detect material noncompliance when it exists. The risk of not detecting material noncompliance resulting from fraud is higher than for that resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Noncompliance with the compliance requirements referred to above is considered material if there is a substantial likelihood that, individually or in the aggregate, it would influence the judgment made by a reasonable user of the report on compliance about the County’s compliance with the requirements of each major federal program as a whole. In performing an audit in accordance with GAAS, Government Auditing Standards, and the Uniform Guidance, we: exercise professional judgment and maintain professional skepticism throughout the audit. identify and assess the risks of material noncompliance, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding County of San Luis Obispo’s compliance with the compliance requirements referred to above and performing such other procedures as we considered necessary in the circumstances. obtain an understanding of the County’s internal control over compliance relevant to the audit in order to design audit procedures that are appropriate in the circumstances and to test and report on internal control over compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness of the County’s internal control over compliance. Accordingly, no such opinion is expressed. We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and any significant deficiencies and material weaknesses in internal control over compliance that we identified during the audit. Report on Internal Control Over Compliance A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. A material weakness in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance. (4) Page 6 of 18 Board of Supervisors County of San Luis Obispo Our consideration of internal control over compliance was for the limited purpose described in the Auditors’ Responsibilities for the Audit of Compliance section above and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies in internal control over compliance. Given these limitations, during our audit we did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses, as defined above. However, material weaknesses or significant deficiencies in internal control over compliance may exist that were not identified. Our audit was not designed for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, no such opinion is expressed. The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the results of that testing based on the requirements of the Uniform Guidance. Accordingly, this report is not suitable for any other purpose. Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance We have audited the financial statements of the governmental activities, the business-type activities, the discretely presented component unit, each major fund, and the aggregate remaining fund information of the County as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the County’s basic financial statements. We have issued our report thereon dated December 29, 2025, which contained unmodified opinions on those financial statements. We did not audit the financial statements of the San Luis Obispo County Pension Trust (SLOCPT), a pension trust fund and First 5 San Luis Obispo (First 5), a discretely presented component unit. Those statements were audited by other auditors whose reports have been furnished to use, and in our opinion, insofar as it relates to the amounts included for SLOCPT and First 5, are based solely on the reports of other auditors. Our audit was conducted for the purpose of forming opinions on the financial statements that collectively comprise the basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the basic financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the basic financial statements as a whole. CliftonLarsonAllen LLP Roseville, California March 30, 2026 (5) Page 7 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients U. S. Department of Agriculture Direct Programs: Emergency Watershed Protection 10.923 NR249104xxxxC045 $ 1,203,489 $ - Passed through State Dept of Health Care Services: 2024 Women Infant Children Nutrition Program 10.557 22-10284 551,291 - 2024 Women Infant Children Nutrition Program - PY 10.557 22-10284 (26,185) - 2025 Women Infant Children Nutrition Program 10.557 22-10284 1,502,001 - Subtotal Assistance Listing Number 10.557 2,027,107 - Passed through State Dept of Food and Agriculture: ACP Bulk Citrus 10.025 23-0026-035-SF, 24-0236-035-SF 5,794 - Glassy-Winged Sharpshooter 10.025 23-0529-036-SF 349,992 - Asian Citrus Psyllid - PY 10.025 23-0026-041-SF (140) - Asian Citrus Psyllid 10.025 24-0236-008-SF 240,484 - European Grape Vine Moth 10.025 23-0729-023-SF, 24-0680-025-SF 32,645 - Phytophthora ramorum (SOD) 10.025 24-0388-016-SF 1,200 - Pest Detection Trapping 10.025 24-0132-049-SF 238,311 - Subtotal Assistance Listing Number 10.025 868,286 - Passed through State Department of Public Health: SNAP Cluster: State Admin. Matching Grants for the Supplemental Nutrition Assistance Program: 2024 Suppl'l Nutrition Asst Prog Ed (SNAP-ED) 10.561 23-10343 66,417 - 2025 Suppl'l Nutrition Asst Prog Ed (SNAP-ED) 10.561 23-10343 337,945 - CalFresh&CalFresh Employment Training (CFET) 10.561 N/A 9,868,800 - CalFresh&CalFresh Employment Training (CFET) - PY 10.561 N/A 267 - Subtotal Assistance Listing 10.561/ SNAP Cluster 10,273,429 - Total U.S. Department of Agriculture $ 14,372,311 $ - U.S. Department of Housing and Urban Development Direct Programs: Community Development Block Grants/Entitlement Grants Cluster: 2017 Community Devel. Block Grants (CDBG) 14.218 B-17-UC-06-0508 $ 11,148 $ 11,148 2018 Community Devel. Block Grants (CDBG) 14.218 B-18-UC-06-0508 19,522 19,522 2019 Community Devel. Block Grants (CDBG) 14.218 B-19-UC-06-0508 19,750 19,750 2020 Community Devel. Block Grants (CDBG) 14.218 B-20-UC-06-0508 230,610 230,610 2021 Community Devel. Block Grants (CDBG) 14.218 B-21-UC-06-0508 49,334 49,334 2022 Community Devel. Block Grants (CDBG) 14.218 B-22-UC-06-0508 486,199 486,199 2023 Community Devel. Block Grants (CDBG) 14.218 B-23-UC-06-0508 158,175 158,175 2024 Community Devel. Block Grants (CDBG) 14.218 B-24-UC-06-0508 1,184,875 935,752 COVID-19 Coronavirus Aid, Relief, Econ. Sec. (CDBG CV2) 14.218 21-CDBG-HK-00025 552,274 466,577 COVID-19 Coronavirus Aid, Relief, Econ. Sec. (CDBG CV3) 14.218 B-20-UW-06-0508 204,978 61,988 Community Development Block Grants/Entitlement Grants - New Loans 14.218 N/A 735,556 - Community Development Block Grants/Entitlement Grants - Existing Loans 14.218 N/A 6,414,873 - Subtotal CDBG - Entitlement Grants Cluster 10,067,294 2,439,055 2024 Emergency Solutions Grant (ESG) 14.231 E-24-UC-06-0508 149,787 138,556 2023 Emergency Solutions Grant (HESG) 14.231 23-ESG-180008 107,948 105,059 Subtotal Assistance Listing Number 14.231 257,735 243,615 2020 Home Investment Partnership (HOME) 14.239 M-20-UC-06-0545 28,748 28,748 2021 Home Investment Partnership (HOME) 14.239 M-21-UC-06-0545 691,305 691,305 2022 Home Investment Partnership (HOME) 14.239 M-22-UC-06-0545 17,818 17,818 2024 Home Investment Partnership (HOME) 14.239 M-24-UC-06-0545 79,764 - COVID-19 2021 Home Investment Partnership (HOME-ARP) 14.239 M-21-UP-06-0545 476,198 362,077 Home Partnership Investment Programs -Existing Lns 14.239 N/A 24,117,733 - Subtotal Assistance Listing Number 14.239 25,411,566 1,099,948 2022 Continuum of Care (Homeless Grants) 14.267 22-CoC-CA-614 246,456 208,641 2023 Continuum of Care (Homeless Grants) 14.267 23-CoC-CA-614 1,190,472 1,053,129 Subtotal Assistance Listing Number 14.267 1,436,928 1,261,770 Total U.S. Department of Housing & Urban Development $ 37,173,523 $ 5,044,388 See accompanying Notes to Schedule of Expenditures of Federal Awards. (6) Page 8 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED) YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients U.S. Department of The Interior Passed through California Bureau of Land Management Distribution of Receipts to State and Local Governments-Taylor Grazing Act 15.227 N/A $ 2,459 $ - Water Recycling and Desalination Construction Program 15.504 N/A 146,779 - Total U.S. Department of Interior $ 149,238 $ - U.S. Department of Justice Direct Programs: Federal Asset Forfeiture 16.000 N/A $ 94,277 $ - 2024 State Criminal Alien Assistance Program 16.606 15PBJA-24-RR-05596-SCAA 190,954 - Joint Law Enforcement Operations Program: FY 2024 DEA Domestic Cannabis Erad & Suppress Prog 16.111 2024-40 59,316 - FY 2024 DEA Domestic Cannabis Erad & Suppress - PY 16.111 2024-40 (252) - FY 2025 DEA Domestic Cannabis Erad & Suppress Prog 16.111 2025-36 2,482 - Subtotal Assistance Listing Number 16.111 61,546 - COPS Technology & Equipment Grant: Bureau of Immigration & Customs Enforcement 16.710 N/A 27,500 - COPS Technology & Equipment Grant 16.710 15JCOPS-22-GG-01465-TECP 1,073,337 - COPS Technology & Equipment Grant 16.710 15JCOPS-24-GG-02093-TECP 1,066,123 - Subtotal Assistance Listing Number 16.710 2,166,960 - Comprehensive Opioid, Stimulant and Substances Use Program: Opioid, Stimulant and Substance Abuse Site-Based 16.838 2020-AR-BX-0126 56,777 23,619 Opioid, Stimulant and Substance Use Site-Based 16.838 15PBJA-23-GG-02359-COAP 357,420 190,600 Subtotal Assistance Listing Number 16.838 414,197 214,219 Treatment Court Discretionary Grant Program: Bureau of Justice Assist Adlt Drg Crt Program 16.585 2018-DC-BX-0013 103,909 9,806 Bureau of Justice Assist Adlt Drg Crt Discret 16.585 15PBJA-21-GG-04261-VTCX 63,547 - Bureau of Justice Assist Adlt Drg Crt Discret - PY 16.585 15PBJA-21-GG-04261-VTCX 47,615 - OJJDP FY 2021 Family Drug Crt Program 16.585 15PJDP-21-GG-04521-COAP 286,354 47,815 OJJDP FY 2021 Family Drug Crt Program - PY 16.585 15PJDP-21-GG-04521-COAP 913 - Subtotal Assistance Listing Number 16.585 502,338 57,621 Bureau of Justice STOP School Violence Program 16.839 15PBJA-22GG-04660-STOP 427,422 404,662 Passed through California Emergency Mgmt Agency: Crime Victim Assistance: Victim Witness Assistance 16.575 VW23420400 153,159 - Victim Witness Assistance 16.575 VW24031201 86,556 - Unserved/Underserved Victim Advocacy (Elder) 16.575 UV23020400 111,794 - Unserved/Underserved Victim Advocacy (Elder) 16.575 UV24031201 3,097 - Subtotal Assistance Listing Number 16.575 354,606 - Direct Programs: 2024 Edward Byrne Memorial Justice Assistance Grant 16.738 15PBJA-24-GG-04626-JAGX 19,620 - Passed through California Emergency Mgmt Agency: 2023 Edward Byrne Memorial Justice Assist (JAG) 16.738 BSCC 626-19 621,492 155,541 2023 Edward Byrne Memorial Justice Assist - PY 16.738 BSCC 1214-23 1 - Subtotal Assistance Listing Number 16.738 641,113 155,541 Total U.S. Department of Justice $ 4,853,413 $ 832,043 U.S. Department of Labor Passed through CA Employment Development Dept: WIOA Cluster: Workforce Investment Act-Adult 17.258 AA411038 $ 515,159 $ 332,955 Workforce Investment Act-Youth 17.259 AA411038 796,936 528,507 Workforce Inv Act-Disloc Workr&Rapid Resp 17.278 AA411038 541,461 304,707 Workforce Inv Act-Disloc Workr&Rapid Resp - PY 17.278 AA411038 (7,220) - Subtotal Assistance Listing Number 17.278 534,241 304,707 Total WIOA Cluster/ U.S. Department of Labor $ 1,846,336 $ 1,166,169 See accompanying Notes to Schedule of Expenditures of Federal Awards. (7) Page 9 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED) YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients U.S. Department of Transportation Direct programs: Airport Improvement Program and Covid-19 Airport Program: FAA AIP Program (SBP Airport MasterPlan) 20.106 3-06-0228-048-2020 $ 35,898 $ - FAA AIP Program (SBP Airport MasterPlan) - PY 20.106 3-06-0228-048-2020 146,020 - FAA AIP Program Runway (PFAS Mitigation) 20.106 3-06-0228-059-2024 195,161 - COVID-19 FAA AIP Program Airport Rescue (ARPA) 20.106 3-06-0228-056-2021 3,493,713 - FAA AIP Program Runway (11-29 Rehab) 20.106 3-06-0172-012-2022 34,074 - FAA AIP Program Runway (11-29 Rehab) - PY 20.106 3-06-0172-012-2022 (1,541) - Subtotal Assistance Listing Number 20.106 3,903,325 - Passed through State Department of Transportation: Highway Planning and Construction - PY 20.205 ER-15J7(029) $ 220,911 $ - Highway Planning and Construction - PY 20.205 ER-15J7(032) 110,172 - Highway Planning and Construction - PY 20.205 ER-15J7(033) 97,710 - Highway Planning and Construction - PY 20.205 ER-15J7(037) 71,783 - Highway Planning and Construction - PY 20.205 ER-15J7(040) 13,062 - Highway Planning and Construction - PY 20.205 ER-15J7(041) 24,987 - Highway Planning and Construction - PY 20.205 ER-15J9(009) 107,307 - Highway Planning and Construction - PY 20.205 ER-15J9(011) 98,542 - Highway Planning and Construction - PY 20.205 ER-15J9(012) 19,922 - Highway Planning and Construction 20.205 HSIPL-5949(158) 269,082 - Highway Planning and Construction 20.205 HSIPL-5949(168) 1,042 - Highway Planning and Construction - PY 20.205 HSIPL-5949(168) 177,128 - Highway Planning and Construction 20.205 HSIPL-5949(177) 38,336 - Highway Planning and Construction 20.205 HSIPL-5949(182) 157,181 - Highway Planning and Construction 20.205 HSIPL-5949(187) 458,308 - Highway Planning and Construction 20.205 HSIPL-5949(192) 38,409 - Highway Planning and Construction - PY 20.205 HSIPL-5949(193) (10,641) - Highway Planning and Construction 20.205 BRLO-5949(128) 67,864 - Highway Planning and Construction 20.205 BRLO 5949(152) 2,232,910 - Highway Planning and Construction 20.205 BRLO-5949(156) 2,326,216 - Highway Planning and Construction 20.205 BRLO-5949(157) 226,391 - Highway Planning and Construction 20.205 BRLO-5949(183) 550,440 - Highway Planning and Construction 20.205 BRLS-5949(131) 4,116,920 - Highway Planning and Construction 20.205 BRLS-5949(135) 3,736,147 - Highway Planning and Construction 20.205 BRLS-5949(137) 462,442 - Highway Planning and Construction 20.205 CMFERP16-5949(161) 5,871,078 - Subtotal Assistance Listing Number 20.205 21,483,649 - Recreational Trails Program: ActiveTransportation Grant 20.219 ATPL - 5949(188) 823,398 - ActiveTransportation Grant 20.219 ATPL - 5949(188) 64,200 - Subtotal Assistance Listing Number 20.219 887,598 - Highway Safety Cluster: State and Community Highway Safety: 2024 Office Of Traffic Safety-Ped&Bicycle 20.600 PS24036 28,587 - 2024 Office Of Traffic Safety-Ped&Bicycle - PY 20.600 PS24036 (114) - 2025 Office Of Traffic Safety-Ped&Bicycle 20.600 PS25018 131,085 - Office of Traffic Safety 20.600 DD24006 130,759 - Office of Traffic Safety - PY 20.600 DD24006 (116) - Subtotal Assistance Listing Number 20.600 290,201 - National Priority Safety Programs: 2024 Office Of Traffic Safety-Child Pass 20.616 OP24015 35,879 - 2024 Office Of Traffic Safety-Child Pass - PY 20.616 OP24015 (5,016) - 2025 Office Of Traffic Safety-Child Pass 20.616 OP25009 113,160 - Subtotal Assistance Listing Number 20.616 144,023 - Subtotal Highway Safety Cluster 724,425 - Total U.S. Department of Transportation $ 26,708,796 $ - U.S. Department of Treasury Direct Programs: COVID-19 Coronavirus Relief Fund - PY 21.019 N/A $ 43,337 $ - COVID-19 Emergency Rental Assistance Program 21.023 21-ERAP-10006 497 - Coronavirus State and Local Recovery Funds: COVID-19 American Rescue Plan (ARPA) 21.027 N/A 13,343,316 1,741,250 COVID-19 American Rescue Plan (ARPA) - PY 21.027 N/A (201,689) - COVID-19 American Rescue Plan Act (ARPA) Discret-Alloc 21.027 N/A 35,036 - COVID-19 American Rescue Plan Act (ARPA) Prevent-Set-Aside 21.027 N/A 15,521 - COVID-19 American Rescue Plan Act (ARPA) Fri-Night-Live 21.027 N/A 5,000 - COVID-19 American Rescue Plan Act (ARPA) Food Bank 21.027 N/A 4,309 - Subtotal Assistance Listing Number 21.027 13,201,493 1,741,250 Total U.S. Department of Treasury $ 13,245,327 $ 1,741,250 See accompanying Notes to Schedule of Expenditures of Federal Awards. (8) Page 10 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED) YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients Institute of Museum and Library Services Direct Programs: Library Services & Technology Act 45.310 LS-253616-OLS-23 $ 3,387 $ - Library Services & Technology Act 45.310 LS-253616-OLS-23 (1,959) - Subtotal Assistance Listing Number 45.310 1,428 - Total Institute of Museum and Library Services $ 1,428 $ - U.S. Department of Health & Human Services Direct Programs: Substance Abuse & Mental Health Services Projects of Regional & National Significance: SAMHSA Adult Drug Court 93.243 1H79TI085507-01 $ 365,699 $ 161,387 SAMHSA Adult Drug Court - PY 93.243 1H79TI085507-01 1 - Subtotal Assistance Listing Number 93.243 365,700 161,387 Centers for Medicare & Medicaid Svcs (CMS) Research, Demonstrations & Evaluations: Targeted Case Management (TCM) - PY 93.779 N/A 1,880 - Block Grants for Community Mental Health Services: Substance Abuse & Mental Hlth Svcs (SAMHSA) 93.958 1B09SM083782-01 408,602 - COVID-19 Mental Health Services Block Grant (MHBG-ARPA) 93.958 1B09SM085337-01 131,436 - Mental Health Services Block Grant (MHBG) 93.958 1B09SM083782-01 361,029 - COVID-19 Mental Health Srvs Block Grant (CRRSAA-CCMU) 93.958 N/A 518,684 518,684 Subtotal Direct Assistance Listing Number 93.958 1,419,751 518,684 Epidemiology & Laboratory Capacity for Infectious Diseases (ELC): ELC Strengthening HAI/AR Program Cap (SHARP) 93.323 N/A 12,625 - COVID-19 ELC ENHANCING DETECTION EXPANSION FUNDING 93.323 COVID-19ELC98 657,679 - COVID-19 ELC ENHANCING DETECT EXPNSN FUNDING - PY 93.323 COVID-19ELC98 (1) - Subtotal Assistance Listing Number 93.323 670,303 - Passed through State Dept of Public Health: Collabration with Academia to Strengthen Public Health: CA Strengthening Public Health Initiative (CASPHI) 93.967 CASPHI0033 103,738 - Passed through State Dept of Alcohol & Drug Programs: Block Grants for Prevention & Treatment of Substance Abuse: Substance Abuse Prev&Trtmt Blck-Discret 93.959 18-95272 1,012,340 672,794 Substance Abuse Prev&Trtmt Blck-Fri Night/Club 93.959 18-95272 46,465 - Substance Abuse Prev&Trtmt Blck-PrevSet-aside 93.959 18-95272 259,738 - Substance Abuse Prev&Trtmt Blck-PrevSet-aside - PY 93.959 18-95272 (664) - Substance Abuse Prev&Trtmt Blck-Adol &Youth 93.959 18-95272 120,005 - Substance Abuse Prev&Trtmt Blck-Adol &Youth - PY 93.959 18-95272 4 - Substance Abuse Prev&Trtmt Blck-Perinatal 93.959 18-95272 72,562 - Subtotal Assistance Listing Number 93.959 1,510,450 672,794 Passed through State Dept of Child Support Svcs: Child Support Services: Federal Aid for Child Support Adm & EDP 93.563 N/A 3,302,399 - Passed Through CA Family Health Council: Family Planning Services: Title X 93.217 88000-5320-2456-200-22.3-24-25 98,155 - Title X - PY 93.217 88000-5320-2456-200-22.3-24-25 300 - Subtotal Assistance Listing Number 93.217 98,455 - Hospital & Public Health Emergency Preparedness Aligned Cooperative Agreements: Health Resources Services Admin HPP 93.074 22-10681 203,286 - CDC-BASE PH EMERGENCY PREPAREDNESS (PHEP) 93.074 22-10681 228,761 - CDC Base PH Emergency Preparedness (LAB) 93.074 22-10681 375,975 - CDC Base PH Emergency Preparedness (LAB) - PY 93.074 22-10681 745 - Subtotal Assistance Listing Number 93.074 808,767 - Project Grants & Cooperative Agreements for Tuberculosis Control Programs: TB FISE Real Time Allotment 93.116 2440BASE00 13,570 - Passed through State Department of Health Care Services: Maternal and Child Health Services Block Grant to States - Title V 93.994 202240 122,194 - See accompanying Notes to Schedule of Expenditures of Federal Awards. (9) Page 11 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED) YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients U.S. Department of Health & Human Services (Continued) Medicaid Cluster:: Grants to States for Medicaid: Medi-Cal Admin (MAA) 93.778 N/A $ 732,955 $ - Medi-Cal Admin (MAA) - PY 93.778 N/A 120,003 - First Five Medi-Cal (CBMAA) 93.778 20-10019 28,700 28,700 First Five Medi-Cal (CBMAA) - PY 93.778 20-10019 3,781 3,781 School Based Medi-Cal Administration - PY 93.778 N/A 325,151 325,151 Maternal Child Health - Title XIX 93.778 202240 1,667,459 - Maternal Child Health - Title XIX - PY 93.778 202240 (25,835) - CA Childrens Services Title XIX (MEDI-CAL) 93.778 N/A 332,048 - CA Childrens Services Title XIX (MEDI-CAL) - PY 93.778 N/A 3,025 - CA Childrens Services Monitoring and Oversight 93.778 N/A 7,597 - Health Care for Fostercare (ADMIN) 93.778 N/A 109,253 - Health Care for Fostercare (BASE) 93.778 N/A 142,651 - Health Care for Fostercare (BASE) - PY 93.778 N/A (3) - Health Care for Fostercare (PMMO) 93.778 N/A 43,903 - Health Care for Fostercare (PMMO) - PY 93.778 N/A (2) - Health Care for Fostercare (Caseload Relief) 93.778 N/A 54,740 - Health Care for Fostercare (Caseload Relief) - PY 93.778 N/A (1) - Childhood Lead Prevention Program (CLPP) 93.778 23-10279 112,799 - Childhood Lead Prevention Program (CLPP) - PY 93.778 23-10279 2,386 - IHSS, Public Authority & Medi-Cal 93.778 N/A 10,332,141 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 151,858 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 454,126 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 102,824 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 69,001 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 11,032 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 20-10019 180,356 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) 93.778 09-86011-A01 21,532 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 150,984 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 98,120 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 (1,904) - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 57,021 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 1,947 - COUNTY MEDI-CAL ADMIN ACTIVITIES (CBMAA) - PY 93.778 20-10019 32,633 - Medi-Cal Administrative Activities 93.778 09-86011-A01 202,459 - Medi-Cal Administrative Activities - PY 93.778 09-86011-A01 179,178 - Providing Access & Transforming Health (PATH-JI) 93.778 1385632-JI 76,060 - Subtotal Grants to States for Medicaid/ Medicaid Cluster 15,779,978 357,632 Passed through State Department of Social Services: KinGap -Kingship Guardian Assistance Program 93.090 N/A 457,304 - Marylee Allen Promoting Safe and Stable Families Program: Promoting Safe and Stable Families 93.556 N/A 157,096 - Promoting Safe and Stable Families - PY 93.556 N/A 1,231 - Refugee and Entrant Assistance 93.556 N/A 1,117 - Refugee Cash Assistance 93.556 N/A 39,350 - Subtotal Assistance Listing Number 93.556 198,794 - Temporary Assistance for Needy Families: Assistance: CalWORKs 93.558 N/A 7,316,523 - Administration: CalWORKS, SAWS-CalWIN, TANF 93.558 N/A 11,895,784 - CalWorks Home Visiting Program (HVP) 93.558 N/A 412,272 - Administration: CalWORKS,SAWS-CalWIN,TANF - PY 93.558 N/A 13,925 - Subtotal Assistance Listing Number 93.558 19,638,504 - Foster Care - Title IV-E: Administration: Probation-Title IV E 93.658 N/A 97,822 - Administration: Probation-Title IV E - PY 93.658 N/A 6,105 - Child Welfare Services - Title IV E 93.658 N/A 4,474,485 - Child Welfare Services - Title IV E - PY 93.658 N/A 54,567 - Foster Care Assistance 93.658 N/A 2,171,336 - Subtotal Assistance Listing Number 93.658 6,804,315 - Adoptions & Legal Guardianship Incentive Payments Program 93.603 N/A 213 - Stephanie Tubbs JonesChild Welfare Services Program - Title IV-B 93.645 N/A 152,281 - Adoption Assistance: Adoption Assistance 93.659 N/A 854,139 - Adoption Assistance - PY 93.659 N/A 6,647 - Assistance: Adoption 93.659 N/A 6,265,767 - Subtotal Assistance Listing Number 93.659 7,126,553 - See accompanying Notes to Schedule of Expenditures of Federal Awards. (10) Page 12 of 18 COUNTY OF SAN LUIS OBISPO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (CONTINUED) YEAR ENDED JUNE 30, 2025 Federal Assistance Federal Grantor/Pass-Through Grantor/ Listing Assistance Listing Number Entity 2024-2025 Passed-Through Program or Cluster Title Number Identifying Number/Grant Number Expenditures to Subrecipients U.S. Department of Health & Human Services (Continued) Passed through State Department of Social Services (Continued): Social Services Block Grant: Child Welfare Service - Title XX 93.667 N/A $ 351,408 $ - Foster Care Assistance - Title XX 93.667 N/A 121,516 - Subtotal Assistance Listing Number 93.667 472,924 - John H. Chafee Foster Care Program for Successful Transition to Adulthood: Independent Living Program 93.674 N/A 113,005 - Independent Living Program - PY 93.674 N/A (61,036) - Subtotal Assistance Listing Number 93.674 51,969 - Childrens Health Insurance Program: CA Childrens Services and TLIP Title XXI (OTLICP) 93.767 20-02 86,829 - Sexually Transmitted Diseases (STD) Prevention and Control Grants: Disease Intervention Specialist Workforce Dev 93.977 21-10583 59,722 - Passed through State Department of Health Care Services: Immunization Cooperative Agreements: Immunization Local Assistance Grant 93.268 22-10054 409,489 - Immunization Local Assistance Grant - PY 93.268 22-10054 300 - Subtotal Assistance Listing Number 93.268 409,789 - Passed through State Department of Mental Health: Mental Health-McKinney Assistance in Transition from Homelessness 93.150 N/A 44,235 44,235 Total U.S Department of Health & Human Services $ 59,700,617 $ 1,754,732 U.S. Department of Homeland Security Direct Programs: Disaster Grants - Public Assistance - PY 97.036 FEMA-4482-DR-CA $ 267,964 $ - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 538,097 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 56,039 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 464,565 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 566,659 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 54,450 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 88,612 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 341,832 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 2,005 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 148,660 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4683-DR-CA 102,109 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4769-DR-CA 32,096 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4699-DR-CA 184,598 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4699-DR-CA 10,108 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4699-DR-CA 198,210 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4769-DR-CA 85,787 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4769-DR-CA 12,106 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4769-DR-CA 5,044 - Disaster Grants - Public Assistance - PY 97.036 FEMA-4769-DR-CA 3,027 - Subtotal Direct Assistance Listing Number 97.036 3,161,968 - Hazard Mitigation Grant Program 97.039 DR-4683-1033-22P 147,543 - Emergency Management Performance Grants: Emergency Management Performance Grant 2022 - PY 97.042 2022-0043 (362) - Emergency Management Performance Grant 2024 97.042 2024-0050 173,350 - 2023 Homeland Security Grant (IT HSGP) 97.042 2023-0006 6,494 - Subtotal Assistance Listing Number 97.042 179,482 - Homeland Security Grant Program: 2021 Stonegarden Grant - PY 97.067 2021-0081 (33,976) - 2022 Stonegarden Grant 97.067 2022-0043 110,779 - 2022 Stonegarden Grant - PY 97.067 2022-0043 (165) - 2023 Stonegarden Grant 97.067 2023-0042 49,665 - COVID-19 Advanced Molecular Detection (AMD#2) 97.067 ELCPHL#08SLO 114,446 - 2022 Homeland Security 97.067 2022-0043 64,816 - 2023 Homeland Security 97.067 2023-0042 68,320 - Homeland Security - Election Security 97.067 2022-0043 10,499 - Subtotal Assistance Listing Number 97.067 384,384 - Total Department of Homeland Security $ 3,873,377 $ - Total Expenditures of Federal Awards $ 161,924,366 $ 10,538,582 See accompanying Notes to Schedule of Expenditures of Federal Awards. (11) Page 13 of 18 COUNTY OF SAN LUIS OBISPO NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS JUNE 30, 2025 NOTE 1 REPORTING ENTITY The accompanying Schedule of Expenditures of Federal Awards (SEFA) presents the activity of all federal award programs of the County of San Luis Obispo (County). The County’s reporting entity is defined in Note 1 to the County’s basic financial statements. Federal awards received directly from federal agencies, as well as federal awards passed through other government agencies, are included in the schedule. The information in this Schedule is presented in accordance with the requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the County, it is not intended to and does not present the financial position, changes in net position, or cash flows of the County. NOTE 2 BASIS OF ACCOUNTING The accompanying Schedule of Expenditures of Federal Awards is presented using the modified accrual basis of accounting and the accrual basis of accounting for program expenditures/expenses accounted for in governmental funds and proprietary funds, respectively, as described in Note 1 of the County’s basic financial statements. Such expenditures/expenses are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures/expenses are not allowable or are limited as to reimbursement. NOTE 3 FEDERAL ASSISTANCE LISTING NUMBERS The program titles and federal assistance listing numbers were obtained from the federal or pass-through grantor. NOTE 4 INDIRECT COST RATE The County did not elect to use the 10% de minimis indirect cost rate as covered in 2 CFR §200.414. NOTE 5 PASS-THROUGH ENTITIES’ IDENTIFYING NUMBER When federal awards were received from a pass-through entity, the Schedule of Expenditures of Federal Awards shows, if available, the identifying number assigned by the pass-through entity. When no identifying number is shown, the County determined that no identifying number is assigned for the program or the County was unable to obtain an identifying number from the pass-through entity. (12) Page 14 of 18 COUNTY OF SAN LUIS OBISPO NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS JUNE 30, 2025 NOTE 6 LOANS WITH CONTINUING COMPLIANCE REQUIREMENTS Outstanding federally funded program loans, with continuing compliance requirements, carried balances as of June 30, 2025 as follows: Federal SEFA FY 24-25 County Balance ALN # Program June 30, 2025 Activity June 30, 2025 14.218 Community Development Block Grants/ $ 7 ,150,429 $ - $ 7,150,429 Entitlement Grants 14.239 HOME Investment Partnerships Program $ 2 4,117,733 $ - $ 24,117,733 (13) Page 15 of 18 COUNTY OF SAN LUIS OBISPO SUMMARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2025 Section I – Summary of Auditors’ Results Financial Statements 1. Type of auditors’ report issued: Unmodified 2. Internal control over financial reporting: Material weakness(es) identified? x yes no Significant deficiency(ies) identified? yes x none reported 3. Noncompliance material to financial statements noted? yes x no Federal Awards 1. Internal control over major federal programs: Material weakness(es) identified? yes x __ _ no Significant deficiency(ies) identified? yes x___ none reported 2. Type of auditors’ report issued on compliance for major federal programs: Unmodified 3. Any audit findings disclosed that are required to be reported in accordance with 2 CFR 200.516(a)? yes x no Identification of Major Federal Programs Assistance Listing Number(s) Name of Federal Program or Cluster 14.218 Community Development Block Grants/ Entitlement Grants 14.239 Home Investment Partnerships 93.558 Temporary Assistance for Needy Families 93.563 Child Support Services 93.658 Foster Care Title IV-E 97.036 Disaster Grants – Public Assistance Dollar threshold used to distinguish between Type A and Type B programs: $ 3,000,000 Auditee qualified as low-risk auditee? yes x no (14) Page 16 of 18 COUNTY OF SAN LUIS OBISPO SUMMARY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2025 Section II – Financial Statement Findings 2025-001 – Restatement of Beginning Fund Balance Condition: For the fiscal year ended June 30, 2025, the County of San Luis Obispo restated its beginning fund balance in the General Fund by a total of $20.1 million. This restatement consisted of: An increase of $15.2 million for revenues from the State of California related to the Medi-Cal program that were incorrectly not recognized in prior years. These amounts had been recorded as a payable because the County anticipated the possibility of repayment to the State. An additional increase of $4.9 million for a receivable related to Medi-Cal that was understated in the prior year. Criteria: Governmental accounting standards require that revenues and receivables be recognized in the appropriate period when they are both measurable and available, and that liabilities be recorded only when a present obligation exists. Cause: The County did not properly evaluate the nature of the Medi-Cal transactions and incorrectly classified certain amounts as a liability rather than revenue. Additionally, the County failed to accurately record the receivable related to Medi-Cal in the prior year. Effect: The misclassification and understatement resulted in a material misstatement of prior-year financial statements and required a restatement of beginning fund balance in the General Fund totaling $20.1 million. Recommendation: The County should strengthen its review and reconciliation processes for Medi-Cal program transactions to ensure proper recognition of revenues, receivables, and liabilities in accordance with applicable accounting standards. Management should implement additional training and oversight to prevent similar errors in future periods. Views of Responsible Officials and planned corrective action: Management agrees with the finding and has provided the department with guidance on proper revenue recognition of Medi-Cal reimbursement transactions. Section III – Findings and Questioned Costs – Major Federal Programs Our audit did not disclose any matters required to be reported in accordance with 2 CFR 200.516(a). (15) Page 17 of 18 Page 18 of 18