Audit 331240

Finding 2023-002 – Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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).” In order for expenditures to be allowable under federal awards, 2 CFR 200.403(a) provides that costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the cost principles. 2 CFR 200.403(g) further provides that costs must be adequately documented. Condition: Management did not have adequately designed internal controls throughout the year over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Section III – Federal Award Findings and Questioned Costs (continued) Cause: Due to the timing of identifying the internal control finding during the 2022 audit, management was not able to timely implement effective internal controls for the entire period under audit for 2023. For certain expenditures, management did not adequately retain invoice or receipt support for non-payroll direct expenditures. Effect or potential effect: Ineffective internal controls could result in expenses being charged to the federal program that are not allowed or are outside the period of performance. Questioned costs: $610. Questioned costs were calculated as the costs without support for the expenditure. Context: Prior to October 15, 2023, payroll controls were designed where the Executive Director reviewed time sheets of the employees working on the program; however, no one reviewed the time submitted by the Executive Director, and if the Executive Director was not available to review the employees’ time sheets, a third-party payroll servicer approved the time. The third-party servicer did not have firsthand knowledge of the activities of each employee. Because the internal controls prior to October 15, 2023, were not designed effectively, we did not test controls over payroll expenditures as they were not in place throughout the audit period. For direct expenses, internal requisitions are to be approved by either the Executive Director or the Assistant Program Director if under $5,000 and by the Executive Director if over $5,000 prior to AdviseWell, Inc. entering into a transaction. Because the internal controls were not implemented timely, we did not test controls surrounding direct expenses. We selected 40 nonpayroll expenditures totaling $13,590 from total nonpayroll expenditures of $590,516 to test allowability, noting that for three selections totaling $610, documentation was not retained to evidence the existence and allowability of the expenditure. For indirect expenses and fringe benefits, the Executive Director calculates the amount and requests reimbursement from the federal program. There was no independent review of the Executive Director’s calculations prior to submitting the request for reimbursement throughout the period under audit. Management asserts that it has internal controls in place to ensure that allowable expenditures are charged to the federal programs within the period of performance. Management did not retain documentation to evidence the internal controls over its review of expenditures to ensure they were within the period of performance. Because evidence of the controls was not retained for the period of performance throughout the entire audit period, we did not test internal controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-001. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls to ensure expenses charged to the federal program are appropriately reviewed and approved by an individual knowledgeable of the program requirements, reviewed prior to entering into the expenditure, and charged within the period of performance. Management should maintain effective segregation of duties. Management should retain invoice or receipt support for all expenditures. View of responsible officials: Management agrees with the finding. Internal controls were enhanced in October 2023 to begin retaining documentation to evidence the controls. Additionally, management will implement internal controls surrounding retaining evidence of expenditures.

Finding 2023-003 – Internal Control Deficiency Cash Management Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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 throughout the audit period of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell, Inc. Cause: Controls were not designed to properly ensure the monthly cash drawdowns were complete and accurate and based on expenses that were paid for by AdviseWell, Inc. Effect or potential effect: Inaccurate requests for reimbursement could occur. Questioned costs: None. Context: A monthly profit and loss statement is generated for each grant within the program. This monthly statement is used to make the monthly request for reimbursement. There was no documentation evidencing that the monthly profit and loss statement was reviewed. Additionally, there was no process in place to ensure that the expenditures have been paid for prior to requesting reimbursement, and in certain instances, the final profit and loss statements were not used. Management performed a reconciliation for amounts requested for reimbursement to the final expenditure detail on the profit and loss statements and noted that, ultimately, actual expenditures of the program exceeded the request for reimbursement. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-002. Recommendation: AdviseWell, Inc. should implement internal controls to ensure requests for reimbursement are based upon final expenses and that any inputs used in the request for reimbursement are reviewed and evidence of that review is retained. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 to retain documentation of the review. Additional controls will be implemented to ensure cash draws are based upon final expenses paid for by AdviseWell, Inc.

Finding 2023-004 – Internal Control Deficiency Reporting Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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: Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The individual who prepares the SF-425 report was the same individual who reviewed and submitted the reports. Cause: Controls were not designed effectively throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission. Effect or potential effect: Reports could reflect inaccurate information. Questioned costs: None. Context: Because there was not appropriate segregation of duties throughout the audit period, we did not test internal controls over reporting. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-003. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission to ensure reports are complete and accurate. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 whereby the person preparing the reports is independent of the person reviewing the reports.

Finding 2023-005 – Internal Control Deficiency and Noncompliance Over Procurement Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) – General procurement standards states: “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 – Methods of procurement to be followed states: ”The non-Federal entity must have and use documented procurements procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded.” Title 2, Subtitle A, Chapter II, Part 200, Subpart C, 200.214 – Suspension and debarment states: “Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: AdviseWell, Inc. did not have internal controls in place throughout the audit period to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price or sole source justification if warranted. Additionally, management did not have evidence of internal controls being in place throughout the audit period to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell, Inc. did not have or use documented procurements procedures throughout the audit period. Cause: Management did not have effective internal controls in place throughout the audit period over the compliance requirement as stated in the criteria section above. Effect or potential effect: Procurements were not supported by effective internal controls and could potentially include unreasonable prices or missing documentation to support the procurements made. If suspension and debarment searches are not conducted, the organization could contract with vendors that are suspended or debarred. Lack of written policies and procedures is out of compliance with the federal requirements and could lead to disallowed procurements. Questioned costs: $80,082. Questioned costs were determined based on the expenditures of the procurements. Context: For five procurements selected for testing totaling $80,082 out of a total population of procurements of $145,646, required documentation was not available supporting the history of the procurement, including rationale for sole source selection. As the written procurement policy was not in place throughout the year and/or documentation of debarment searches on vendors was not maintained throughout the year, we were unable to test these controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-004. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to ensure procurements are in accordance with the federal guidelines. AdviseWell, Inc. should search for suspension and debarment prior to entering into a procurement transaction and retain documentation that the search was conducted prior to entering into the transaction. AdviseWell, Inc. should periodically search recurring vendors for suspension and debarment and retain documentation to support that the search was conducted. View of responsible officials: Management agrees with the finding. A procurement policy was established in October 2023 in accordance with the federal requirements, and documentation for each procurement was retained subsequent to October 2023. Management began retaining documentation that searches were conducted for vendors for suspension and debarment prior to entering into the procurement and on a periodic basis for recurring vendors.

Finding 2023-002 – Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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).” In order for expenditures to be allowable under federal awards, 2 CFR 200.403(a) provides that costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the cost principles. 2 CFR 200.403(g) further provides that costs must be adequately documented. Condition: Management did not have adequately designed internal controls throughout the year over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Section III – Federal Award Findings and Questioned Costs (continued) Cause: Due to the timing of identifying the internal control finding during the 2022 audit, management was not able to timely implement effective internal controls for the entire period under audit for 2023. For certain expenditures, management did not adequately retain invoice or receipt support for non-payroll direct expenditures. Effect or potential effect: Ineffective internal controls could result in expenses being charged to the federal program that are not allowed or are outside the period of performance. Questioned costs: $610. Questioned costs were calculated as the costs without support for the expenditure. Context: Prior to October 15, 2023, payroll controls were designed where the Executive Director reviewed time sheets of the employees working on the program; however, no one reviewed the time submitted by the Executive Director, and if the Executive Director was not available to review the employees’ time sheets, a third-party payroll servicer approved the time. The third-party servicer did not have firsthand knowledge of the activities of each employee. Because the internal controls prior to October 15, 2023, were not designed effectively, we did not test controls over payroll expenditures as they were not in place throughout the audit period. For direct expenses, internal requisitions are to be approved by either the Executive Director or the Assistant Program Director if under $5,000 and by the Executive Director if over $5,000 prior to AdviseWell, Inc. entering into a transaction. Because the internal controls were not implemented timely, we did not test controls surrounding direct expenses. We selected 40 nonpayroll expenditures totaling $13,590 from total nonpayroll expenditures of $590,516 to test allowability, noting that for three selections totaling $610, documentation was not retained to evidence the existence and allowability of the expenditure. For indirect expenses and fringe benefits, the Executive Director calculates the amount and requests reimbursement from the federal program. There was no independent review of the Executive Director’s calculations prior to submitting the request for reimbursement throughout the period under audit. Management asserts that it has internal controls in place to ensure that allowable expenditures are charged to the federal programs within the period of performance. Management did not retain documentation to evidence the internal controls over its review of expenditures to ensure they were within the period of performance. Because evidence of the controls was not retained for the period of performance throughout the entire audit period, we did not test internal controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-001. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls to ensure expenses charged to the federal program are appropriately reviewed and approved by an individual knowledgeable of the program requirements, reviewed prior to entering into the expenditure, and charged within the period of performance. Management should maintain effective segregation of duties. Management should retain invoice or receipt support for all expenditures. View of responsible officials: Management agrees with the finding. Internal controls were enhanced in October 2023 to begin retaining documentation to evidence the controls. Additionally, management will implement internal controls surrounding retaining evidence of expenditures.

Finding 2023-003 – Internal Control Deficiency Cash Management Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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 throughout the audit period of internal controls in place to ensure that requests for reimbursement are based on expenses paid for by AdviseWell, Inc. Cause: Controls were not designed to properly ensure the monthly cash drawdowns were complete and accurate and based on expenses that were paid for by AdviseWell, Inc. Effect or potential effect: Inaccurate requests for reimbursement could occur. Questioned costs: None. Context: A monthly profit and loss statement is generated for each grant within the program. This monthly statement is used to make the monthly request for reimbursement. There was no documentation evidencing that the monthly profit and loss statement was reviewed. Additionally, there was no process in place to ensure that the expenditures have been paid for prior to requesting reimbursement, and in certain instances, the final profit and loss statements were not used. Management performed a reconciliation for amounts requested for reimbursement to the final expenditure detail on the profit and loss statements and noted that, ultimately, actual expenditures of the program exceeded the request for reimbursement. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-002. Recommendation: AdviseWell, Inc. should implement internal controls to ensure requests for reimbursement are based upon final expenses and that any inputs used in the request for reimbursement are reviewed and evidence of that review is retained. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 to retain documentation of the review. Additional controls will be implemented to ensure cash draws are based upon final expenses paid for by AdviseWell, Inc.

Finding 2023-004 – Internal Control Deficiency Reporting Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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: Evidence of internal controls was not in place throughout the audit period to ensure that reports which are submitted are complete and accurate. The individual who prepares the SF-425 report was the same individual who reviewed and submitted the reports. Cause: Controls were not designed effectively throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission. Effect or potential effect: Reports could reflect inaccurate information. Questioned costs: None. Context: Because there was not appropriate segregation of duties throughout the audit period, we did not test internal controls over reporting. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-003. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to properly segregate duties whereby someone independent of the preparer is reviewing the reports prior to submission to ensure reports are complete and accurate. View of responsible officials: Management agrees with the finding. Controls were enhanced in October 2023 whereby the person preparing the reports is independent of the person reviewing the reports.

Finding 2023-005 – Internal Control Deficiency and Noncompliance Over Procurement Identification of the federal program: Federal grantor: United States Department of Health and Human Services Assistance listing no.: 93.048 Program name: Special Programs for the Aging, Title IV, and Title II, Discretionary Projects Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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).” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318(i) – General procurement standards states: “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.320 – Methods of procurement to be followed states: ”The non-Federal entity must have and use documented procurements procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award: (a) (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity; (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the simplified acquisition threshold, or a lower threshold established by a non-federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded.” Title 2, Subtitle A, Chapter II, Part 200, Subpart C, 200.214 – Suspension and debarment states: “Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: AdviseWell, Inc. did not have internal controls in place throughout the audit period to sufficiently document the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price or sole source justification if warranted. Additionally, management did not have evidence of internal controls being in place throughout the audit period to document that vendors were not suspended or debarred prior to entering into a procurement transaction. AdviseWell, Inc. did not have or use documented procurements procedures throughout the audit period. Cause: Management did not have effective internal controls in place throughout the audit period over the compliance requirement as stated in the criteria section above. Effect or potential effect: Procurements were not supported by effective internal controls and could potentially include unreasonable prices or missing documentation to support the procurements made. If suspension and debarment searches are not conducted, the organization could contract with vendors that are suspended or debarred. Lack of written policies and procedures is out of compliance with the federal requirements and could lead to disallowed procurements. Questioned costs: $80,082. Questioned costs were determined based on the expenditures of the procurements. Context: For five procurements selected for testing totaling $80,082 out of a total population of procurements of $145,646, required documentation was not available supporting the history of the procurement, including rationale for sole source selection. As the written procurement policy was not in place throughout the year and/or documentation of debarment searches on vendors was not maintained throughout the year, we were unable to test these controls. Identification as a repeat finding, if applicable: This is a repeat finding – Finding 2022-004. Recommendation: AdviseWell, Inc. should develop and implement effective internal controls throughout the audit period to ensure procurements are in accordance with the federal guidelines. AdviseWell, Inc. should search for suspension and debarment prior to entering into a procurement transaction and retain documentation that the search was conducted prior to entering into the transaction. AdviseWell, Inc. should periodically search recurring vendors for suspension and debarment and retain documentation to support that the search was conducted. View of responsible officials: Management agrees with the finding. A procurement policy was established in October 2023 in accordance with the federal requirements, and documentation for each procurement was retained subsequent to October 2023. Management began retaining documentation that searches were conducted for vendors for suspension and debarment prior to entering into the procurement and on a periodic basis for recurring vendors.