Corrective Action Plans

The Garden is in the process of reviewing its policy surrounding the review process for federal expenditures. The Garden will be implementing an approval process for all expenses on credit cards and other federal charges. Accounting will only charge the expense to the grants once it has verified the expense has gone through the proper approval channels.

We already implemented a formal review and approval process in 2023 and anticipate this finding to be resolved on our next year audit. We will also ensure the review and approval is properly documented.

Panthera implemented Chrome River which is a platform that enables electronic review and approval of invoices as part of Panthera’s expense management process. As Panthera expands its operations internationally we plan to implement more controls and procedures to ensure foreign affiliates are properly maintaining all required expenditures documentation and approvals on spending.

Panthera implemented an approval workflow in Chrome River, but we will also ensure a formal written approval is issued on quarterly expenditure reports going forward.

FINDING 2022-002 Finding Subject: Allowable Costs/Cost Principles Summary of Finding: Indirect costs are expenses that are incurred by other County offices, which indirectly benefit the County Title IV-D offices. Indirect expenses are allocated to the County Title IV-D offices through an indirect Cost Allocation Plan (CAP) which is submitted to the Department of Child Services’ Child Support Bureau. Indirect costs charged are based on twoyear prior expenditures; therefore, indirect costs charged in 2022 were based on expenditures from 2020. A sample of 25 expenditures, totaling $27,077, from the department cost pools from the CAP were selected for testing. For 1 of the 25 expenditures examined, the County was unable to provide the contract; therefore, we were unable to verify if the correct rate for the contract payment was charged. For an additional 2 contracts requested, the contract could not be provided at the initial time of request. The contracts were provided nine months later at which time we verified the contract payment charged. In addition, the County did not have written procedures for determining the allow ability of costs in accordance with Subpart E of 2CFR200. Contact Person Responsible for Corrective Action: James W. Bramble Contact Phone Number and Email Address: 812-462-3361 james.bramble@vigocounty.in.gov Views of Responsible Officials: We disagree with the finding Explanation and Reasons for Disagreement: Of the three contracts that were found to be non-compliant, one contract was a 2014 contact with a one year termination that provided for courthouse cleaning services. After the termination date of contract the agreement was verbally continued by the County Commissioners. The examiners were provided copies of that contract and signed copies of the other two contracts that were in effect during the audit period. The County Auditor was provided information by the examiners on the specific contracts in question on June 4, 2024 and copies of the contracts were provided on June 7, 2024. That is three days later, not nine months as alleged in the finding. Description of Corrective Action Plan: The County currently has a signed contract with a different contractor for courthouse cleaning services than the one in 2014. The current contract has a provision that it is to be continued until terminated by either party. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Page 2 Corrective Action Plan, Vigo County Anticipated Completion Date: January 31, 2025

Finding Number: 2022-004 Finding Title: Reporting Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (AL No. 21.027) Name of Contact Person Responsible for Corrective Action: David Stene, CFO Corrective Action Planned: Have the report reviewed by other county staff prior to sending in the report. Anticipated Completion Date: 12/31/2023

Finding Number: 2022-003 Finding Title: Suspension and Debarment Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (AL No. 21.027) Name of Contact Person Responsible for Corrective Action: David Stene, CFO Corrective Action Planned: For future projects, a vendor who has one expenditure or cumulative expenditures totaling $25,000 and above of federal aid dollars, the respective department head or staff must access SAM.GOV to research that vendor for suspension and/or debarment. Anticipated Completion Date: 12/31/2023

Contact Person Megan Rath 2022-003 Corrective Action Plan The USDA was made aware that the financial statements had errors and were unaudited at the time of the submission of the RD 442-2 and RD 442-3 for 2022. The Association’s audited financial statements are now up to date. Proper checks and balances have been put into place to ensure ongoing complete and accurate financial data for USDA reporting. Completion Date The corrective action plan steps are planned to be sufficiently in place prior to the beginning of the 2023 USDA required reporting.

Criteria or specific requirement: 2 CFR 200.403(b) states that costs must "Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items". Per the Federal award (contract 2018-51300-28430, PTEIN C0535A-A), there was no specific allowability for “Fees”, and the budget indicated $0 allocated to “Fees”. 2 CFR 200.303(a) requires non federal entities receiving Federal awards to "Establish and maintain internal controls 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." 2 CFR 200.430(i)(1) states that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed." Condition: (10.307) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 4 out of 17 samples tested. In addition, for 1 sample, the Organization charged unallowable costs (bank fees) to the major program. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 26 samples tested, resulting in wages being charged erroneously between programs. (10.311) During testing of general disbursements, it was noted that the Organization did not retain documentary evidence of review and approval of disbursements for 5 out of 14 samples tested. During testing of payroll, it was noted that inadequate time and effort documentation was retained for 2 out of 21 samples tested, resulting in wages being charged erroneously between programs. During testing of indirect costs, it was noted that direct costs used to calculate the applied indirect cost rate were not supported by underlying documentation of costs incurred. Questioned costs: None Context: (10.307) For testing of general disbursements, a sample of 17 was made from a population of 113 disbursement transactions. Of the 17 sampled, 4 did not include documentary evidence of review and approval of the disbursement. In addition, 1 sample was found to be out of compliance with the provisions for 2 CFR 200.403(b). For testing of payroll, a sample of 26 was made from a population of 168 unique employee paychecks. Of the 26 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. (10.311) For testing of general disbursements, a sample of 14 was made from a population of 90 disbursement transactions. Of the 14 sampled, 5 did not include documentary evidence of review and approval of the disbursement. For testing of payroll, a sample of 21 was made from a population of 139 unique employee paychecks. Of the 21 sampled, 2 had inadequate documentation of time and effort spent on the major program, resulting in an overbilling in one sample and an underbilling in the second sample. For testing of indirect costs, a sample of 6 was made from a population of 21 monthly reimbursement invoices. Of the 6 sampled, 3 did not include sufficient documentation to support the direct costs used to apply the indirect cost rate. Cause: The Organization does not have adequate controls around the documentation of the supervisor review and approval process. Supervisory review and approvals are currently being communicated verbally. In addition, inadequate documentation is retained to document the time and effort of employee time spent on grants and the total direct costs that should be considered when applying the indirect cost rate. Effect: Without adequate records retained, the Organization is at risk of noncompliance with Federal programs and grant regulations, which could result in penalties or repayment obligations. Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, the Organization could incorrectly charge expenditures to the Federal program, report fraudulent expenditures, or not request appropriate reimbursement that the Organization is entitled to under the terms of the grant. Repeat Finding: No Recommendation: CLA recommends for the Organization to evaluate its current policies and procedures to implement an additional layer of review, and to formally document such review and approval procedures for all transactions affecting federal funds (i.e. approval of general expenditures, approval of timesheets, approval of indirect cost allocations). In addition, the Organization should emphasize the importance of detailed reviewed timesheets, including a second level review by the Finance Manager to ensure the accuracy and documentation of time and effort billed to each Federal program. Views of responsible officials: Management agrees with the finding. Action Taken in Response to Finding: In response to these findings, OSA has reviewed its formal review and approval procedures to ensure that documentation of review and approval occurs with payroll time cards and wage reporting to grants. In response to this review, OSA has implemented the following: ● Adherence to a current and accurate Financial Management Policy Manual. The manual documents OSA’s policy and procedures regarding this finding: ○ Monthly close/reconciliation reviewed by Executive Director and Board of Directors. ○ Review and approval of all allowable federal expenditures including payroll wage reporting to federal programs, and invoices by OSA Executive Director or federal program Director. ○ Archiving a digital copy of review and approvals for every invoice submitted, including review and approval for all supporting documentation including approved timesheets. Name(s)of the Contact Person Responsible for Corrective Action: Laurajean Lewis, Executive Director, at laurajean@seedalliance.org Planned Completion Date for Corrective Action Plan: 06/01/2024

Criteria or specific requirement: 2 CFR 200.303(a) requires non federal entities receiving Federal awards to "Establish and maintain internal controls 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." Per the United States Department of Agriculture SF-425 FAQs, SF-425 Reports are to be submitted within 90 days of the anniversary date of the award. Condition: During testing it was noted that the financial report tested was filed after the required filing deadline. In addition, there was no evidence of review or approval over the report filing prior to submission to the granting agency. Questioned costs: None Context: A sample of 1 was made from a population of 1 financial report (entire population). The financial report did not have documentary evidence of review and approval. In addition, the report was filed after the submission deadline date. Cause: Documentary evidence of supervisor review and approval of the SF-425s is not retained. Rather, such approval is only communicated verbally. In addition, the Organization does not currently have monitoring procedures in place to ensure reports are submitted timely. Effect: Not filing reports on a timely basis can present risks, such as outdated and unreliable information or the inability to detect potential fraud or irregularities. In addition, delayed reports can impede regulatory authorities' ability to monitor compliance, detect patterns or trends, and assess risks in a timely manner. Without adequate documentary evidence around the review of financial reports, there is an increased risk of errors and fraud in the reporting process, which could result in inaccurate financial reporting and misappropriation of funds. Repeat Finding: No Recommendation: CLA recommends for the Organization to place emphasis on stronger controls around the timely filing of required reports, such as retaining a monthly checklist of required reconciliations and reports. CLA also recommends implementing a procedure that documents the supervisor's review (another individual who did not prepare the report) and approval of the Federal Financial Reports (SF-425s), whether that be via an email chain or retaining a copy that also includes the supervisor's signature on the report. Views of responsible officials: Management agrees with the finding. Action Taken in Response to Finding: In response to these findings, OSA has reviewed its formal review and approval procedures to ensure that documentation of review and approval occurs with every federal expense and invoice, and all federal reports are submitted accurately and on-time. In response to this review, OSA has implemented the following: ● Adherence to a current and accurate Financial Management Policy Manual. The manual documents OSA’s policy and procedures regarding this finding: ○ Monthly close/reconciliation reviewed by Executive Director and Board of Directors. ○ Review of federal grant requirements by OSA Leadership Team to support the finance manager, to ensure all federal financial reports are filed accurately and on time. ○ Review and approval of all allowable federal expenditures and invoices by the OSA Executive Director. ○ Archiving a digital copy of review and approvals for every invoice submitted, including review and approval for all supporting documentation including approved timesheets. Name(s) of the Contact Person Responsible for Corrective Action: Laurajean Lewis, Executive Director, at laurajean@seedalliance.org Planned Completion Date for Corrective Action Plan: 06/01/2024

The Uniform Guidance required that a grantee must establish and maintain records adequately reflecting the source and application of funds with information including authorizations, unobligated balances, expenditures, and income and that these be supported by source documentation that must be retained for three years from the final expenditure report. Requests for reimbursement and their supporting information could not be located for three of six reimbursement requests. We recommend that a standardized file and documentation system be implemented for all grant reimbursement requests containing the reimbursement request with evidence of review and authorization and including the supporting expenditure reports. Views of Responsible Officials and Planned Corrective Actions: The Academy has contracted with an accounting and administrative contractor who has implemented a recordkeeping system for grant reimbursement requests and related supporting documentation.

here was inadequate oversight of activities and information provided by the contractor resulting in a material overstatement of meals claimed for the current year. Sufficient controls were not in place for the current fiscal year to ensure that an accurate meal count was claimed for USDA reimbursement. We recommend that a knowledgeable person be assigned responsibility for oversight of the child nutrition program. We further recommend procedures be implemented to provide oversight of contractor services and information provided including a review process for the USDA claims requests. Views of Responsible Officials and Planned Corrective Actions: The Academy has employed a supervisor responsible for overseeing the child nutrition program and the contract with the previous provider has terminated. Further, the Academy currently provides onsite meal service beginning with the 2022-23 school year provided by a new contractor.

ACL Centers for Independent Living – Assistance Listing No. 93.435 Type of Finding: Allowable Activities and Allowable Costs – Payroll Disbursements • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, non-Federal entities 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 statues regulations, and the terms and conditions of the Federal award.” Condition: Payroll allocation review is performed annually by ED, which is not timely enough to accurately reflect employee's time worked. Additionally, the allocation performed had logical errors, including one employee’s time missing from the allocation calculation, and using an inappropriate allocation basis. Questioned costs: None Context: All employees included in selection deemed to work positions that are allowable to the program, however the client allocation process unreliable for all sections tested (25). Cause: Allocations to program based on one employee's memory (ED) for full-year organizational operations. Allocations not reviewed for accuracy by other individual. Effect: Currently, all assigned work activities employees engage in are theoretically allowable under the program, however if an employee were to work projects that are not allowable under the Federal award, reimbursement requests could be made for unallowable costs. Repeat Finding: No Recommendation: 1) Have employees enter time by period and ensure time codes reflect type of activities worked that tie to Federal program allocations. 2) Have ED review employee timesheets each pay period. 3) Review allocations by program each pay period. 4) Have a second individual (contract accountant) review allocations to ensure accuracy and completeness. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: DEC employees enter their time by period and code activities to the corresponding programs. Program Directors, then the ED reviews all employees time sheets and allocations each pay period. DEC’s contract accountant reviews monthly. Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck, Executive Director Planned completion date for corrective action plan: Already implemented.

ACL Centers for Independent Living – Assistance Listing No. 93.435 Type of Finding: Allowable Activities and Allowable Costs – General Disbursements • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, non-Federal entities 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 statues regulations, and the terms and conditions of the Federal award. Condition: Documentation not maintained to support one cash disbursement. Questioned costs: None Context: 1/40 of the general disbursements tested lacked indication of approval. Deemed to be an isolated incident as the vendor in question provides physical receipts to DEC, which is an unusual and infrequent method. Limited transactions with said vendor. Cause: Vendor purchases are in-person and physical receipt is obtained. This is unusual for common vendors used and leads to more opportunity for documentation loss. Effect: Reimbursement requests could be made for unallowed expenditures. Repeat Finding: No Recommendation: Review document retention process to ensure all costs that are charged to a federal program are adequately reviewed and documentation of that process is maintained. If documentation is not available, costs should not be charged to the Federal program. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: This was an isolated incident and DEC now takes steps to digitally record physical receipts with a photograph as soon as possible. Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck, Executive Director Planned completion date for corrective action plan: Already implemented.

CORRECTIVE ACTION PLAN Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: 21.027 Federal Agency: Department of the Treasury ? Pass-through from the State of California Award No.: WWID 4SSO10370 & CA 1910156 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs Name responsible for correction action plan: Emily Armstrong, Revenue Services Manager The corrective action planned: Payments applied to the 93 water bills and 81 wastewater bills will be reversed on the customer?s accounts. A notice will be issued to customers via mail and email (where possible) of the discrepancy. The funds will be returned to the State pursuant to their outlined procedures. Moving forward, the City will ensure that there is a multi-layered approval process to review the eligibility period of any State funding to identify the correct eligible applicants prior to disbursement. For future funding related to water and/or waster bills, the list of eligible applicants will be compiled by an analyst within the department and will be reviewed by the Revenue Services Manager and Assistant Finance Director prior to disbursement. Anticipated completion date: March 24, 2023

The Metcalfe County Fiscal Court contracted with an outside entity to manage the CSLFRF disbursements and reporting requirements. We entrusted that we were in compliance for all federal program expenditures where these funds were concerned. Prepared by: County Treasurer Page Edwards Date Prepared: March 6, 2023 Person Responsible for Corrective Action Plan: Judge/Executive Larry Wilson Anticipated Completion Date: July 1, 2023

Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.

A consistent and substantiated methodology for accounting for indirect costs to be allocated was implemented in FY 23 and remains in place. Anticipated Completion Date-Completed.Responsible Contact Person-Kathleen Boyce, CFAO

2022-005 Temporary Aid for Needy Families (TANF) Federal Financial Assistance Listing Number: 93.558 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 1946001347-A7 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Department of Social Services agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The Count of Imperial, Department of Social Services, is committed to maintaining robust monitoring and oversight controls in place to ensure that applicant eligibility is thoroughly reviewed and approved. The Department will continue to monitor compliance with policies to ascertain that eligibility technicians follow guidelines for redetermination of recipients of need and amount of assistance, including to retain acceptable documentation to support the determinations. The Department will implement enhances training and guidance to include refresher training that will be developed based on needs identified during this review. The training will address any changes in regulations and/or internal processes. Name of Responsible Person: Paula S. Llanas, County of Imperial – Department of Social Services Director Implementation Date: September 1, 2024

2022-007 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA111008 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: ICWDO acknowledges the recommendation and is actively working on a remedy and on the development of formal policies as recommended, which will assist ICWDO’s fiscal team in ensuring that all reports are appropriately reconciled. ICWDO acknowledges the recommendations from finding 2021-010 related to a formalization of the Administrative/fiscal processes and protocols to ensure that procedures are consistently followed to guarantee that reports agree to the amounts recorded in the general ledger and SEFA. Additionally, the recommendation specifics that protocols to ensure the separation of duties are featured in the policy. ICWDO operates under WIOA guidelines and follows County fiscal/administrative policies. Internal policies that include formal controls and procedures to ensure that monthly reports and general ledgers are consistent, with clear segregation of duties will be formally adopted. Aspects of these policies will include: • Protocol for preparation of monthly reports by the fiscal manager, and approval and signature by ICWDO Director • Protocol for preparation of closeouts that will provide the hierarchy of development, review, and approval for future reference. • Schedule monthly closeout meetings with the fiscal department and administration to ensure that documents are reviewed separately, and issues are addressed promptly. • Protocol for Policy Committee review, comment and direction, and approval for implementation by vote of the full workforce development board. ICWDO anticipates to implement the corrective action by December 31, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023

2022-006 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023

Finding 2022-004: Payroll Federal Programs: Research and Development Cluster: 47.0746 Condition: Payroll approvals for individuals are not always made by individuals who are the employee's supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO

The Director of Finance and Accounting Manager will work with the Grants and Contract Accountant to coordinate grant kickoff meetings with Program Directors and Managers to ensure they have procedures in place to meet the requirements for the agreement. These meetings will be held in August and September.

Finding: 2022-001 Material Weakness over SEFA Preparation Federal Agency: U.S. Department of State Federal Program: Overseas Refugee Assistance Program for Near East (ALN 19.519) Contact Person: Corey Dillow, Senior Managing Director, Financial Controller Criteria 2 CFR 200.510 (b)(3) requires non-Federal entities receiving Federal award to (at minimum) provide total Federal awards expended for each individual Federal program and the Assistance Listings Number. Internal controls around the identification of ALNs and reporting of the SEFA should ensure proper presentation for each ALN number. Condition and Context During our planning meetings with management, we were notified that an award was recorded to an incorrect ALN in the 2022 Schedule of Expenditures of Federal Awards. The 2022 Schedule of Expenditures of Federal Awards was corrected and an additional major program, Overseas Refugee Assistance Program for Near East (ALN 19.519), was identified. Corrective Action: As result of the finding, management will be implementing the below steps to further refine internal controls in the identification and reporting of ALNs in the SEFA by: 1. Reinforcing the importance of ALN assignment and tracking through training. 2. Including the ALN attribute as a required element for award setup reviews. 3. Conducting periodic checks of ALNs to source agreements. 4. Documenting and performing additional SEFA data quality checks. Anticipated Completion Date: July 2024

Action Item Title 2022-002 – Financial Management and Internal Controls Compliance Requirement Allowable Costs/Cost Principles Status (Open: In-process) Condition Written Policies The Corporation has no written policies for determining the activities allowed or unallowed and the allowability of costs as described in subpart E, Cost Principles of 2 CFR Part 200. Identified root cause It is the first year for the Corporation to be subjected to a single audit compliance requirement. However, since the Commonwealth of Puerto Rico (the Commonwealth) filed for Title III under the PROMESA, all the instrumentalities of the Commonwealth had to reduce their staff as part of the Fiscal Plan to reduce expenditures. This has disrupted the segregation of duties, which is a key control. Grantee resolution plan Written Policies The Corporation received federal funds for the first time in 2022. For the purposes of purchases or acquisitions, the Corporation is governed by Law of the General Service Administration for the Centralization of Government Purchases in Puerto Rico, Law No. 73 of 2019, which establishes the uniform purchasing process for acquisitions by the Commonwealth. The Corporation will adopt regulations for the use and disbursement of federal funds and comply with the federal regulations. Completion Date Written Policies By June 30, 2025 Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov