Corrective Action Plans

COVID-19: Coronavirus State and Local Fiscal Recovery Funds: Workforce Innovation Grant – Assistance Listing No. 21.027 Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization plans to review its procurement and suspension and debarment policies and asses necessary changes to be in accordance with Uniform Guidance going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2025

SINGLE AUDIT FOR THE YEAR ENDED SEPTEMBER 30, 2024 CORRECTIVE ACTION PLAN FEDERAL AWARD FINDINGS - Fiscal Year 2024 Finding Number: 2024-001 Procurement Assistance Listing Number: 93.696 Assistance Listing Title: Certified Community Behavioral Health Clinics N ame of Federal Agency: Substance Abuse and Mental Health Services Administration Federal Award Identification Number: H79SM089299 Fiscal Year of Initial Finding: 2024 • Name of the contact person: Tina Boyer, CFO • Corrective Action Plan: Management agrees with this recommendation. VBCMH management will review and update policies and procedures to ensure that allfederal requirements are followed. Anticipated Completion Date: Fiscal Year 2025

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $77,285 Prior Year Finding: FA 2023-001 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us

- We now implemented a best practice to require that a contractor submitting a bid or sub awardees affirms that they are not debarred, suspended or otherwise ineligible for federal funding during contracting with IFPA. We save their email response and include the file in any future audits. - As a best practice, we will make every attempt to avoid sole-sourcing. In cases where solesourcing is unavoidable, we will document and file the sole-source justification of services to be procured from contractors or sub awardees in which it applies in the form of former contacts or otherwise written confirmation - As a result, we will draft and adopt a formal procurement policy.

Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements. To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions: 1. Procurement Policy Review with External Expertise: NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight. 2. Update and Alignment of Procedures: With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals). 3. Ongoing Education and Training: NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance. 4. Internal Controls and Review Process: A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action. 5. Monitoring and Quarterly Compliance Checks: The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight. Timeline for Implementation: • External Consultant Engagement: Completed – May 2025 • Policy and Procedure Review: To be completed by July 31, 2025 • Initial Staff Training: To be conducted by August 15, 2025 • Internal Controls & Monitoring: To be fully implemented by August 31, 2025 • Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter Anticipated Full Compliance Date: August 31, 2025 Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004) Responsible Party: Chief Financial Officer, Carlett Gregory

Condition: Prisma Health's written procurement policy and procedures are not compliant with the requirements of the Uniform Guidance (2 CFR Part 200). This includes the absence of a documented policy outlining the different procurement methods, related thresholds, necessary documentation, and steps to ensure full and open competition when using federal funds. Planned Corrective Action: Prisma Health acknowledges this finding and will develop and implement a Uniform Guidance compliant procurement policy within the next month. The policy will be reviewed and approved by the CFO, head of Procurement and representatives of the Grants team. Contact person responsible for corrective action: Matt Elsey, Executive Vice President and CFO Anticipated Completion Date: 7/31/2025

The District of Columbia Public Library (DCPL) concurs with the auditor’s findings and recommendations. Management acknowledges the finding regarding the procurement that was awarded prior to receiving the federal funding and the procurement did not fully adhere to the standards outlined in 2 CFR Section 200. The Procurement was awarded under the District’s Municipal Regulations policies and procedures, we recognize that the 2 CFR Section 200 requirements are stricter. Effective June 12, 2025, DCPL will ensure that all Procurements comply with 2 CFR Section 200, including procurements awarded prior to receiving Federal funding. This includes: • Enhancing our internal review process and documentation to confirm the funding source and ensure Federal procurement regulations are followed. • Identify training for Procurement, Budget and Program Staff on Federal grant compliance and Procurements that fall under 2 CFR Section 200. Contact: Richard Reyes-Gavilan, Executive Director Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendors were not excluded from federal contracts due to debarment or suspension. Corrective Action Taken: Procurement findings: 1. Performance Foodservice had two (2) invoices dated May 2023 (FY23) paid in FY24. For FY23 the BOE had a contract with Performance. The invoices were for prior year. No purchases were made in FY24, only payment from FY23 purchases. BOE believes the purchasing policy was followed. 2. Sardilli Produce, had 3 PO’s entered in FY24. One PO was for $80,000 for yearly invoices. 58 invoices were charged to PO. Average invoice total was $1,289. The approved PO did not follow purchasing policy. Suspension and Debarment addressed in 2024-005. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures related to procurement in March of 2024. See FY23 Corrective Action Plan. However, the one procurement sample that was cited as not including “documentation of bidding, alternative price quotes or sole source documentation” contained a sole source justification that was developed before implementation of the FY23 Corrective Action Plan. The sole source justification was based on the specialized knowledge and specific expertise. Procurement samples for purchases or contracts after the implementation of the FY23 Corrective Action Plan, show compliance of adequate bidding, price quotes or sole source documentation consistent with 2 CFR 200. The NWIFC will continue to implement the FY23 Corrective Action Plan, by requiring NWIFC managers and their staff to be responsible for soliciting bids or developing sole source justifications for procurements and contracts consistent with 2 CFR 200. The Contract Specialist will ensure that bid solicitations and sole source justifications are properly documented and filed with each contract. Similarly, the audit noted that certain suspension and debarment samples selected, before the FY23 Corrective Action Plan was implemented in March 2024, lacked documentation of a suspension and debarment review prior to doing business with vendors. In response, the FY23 Corrective Action Plan, put into effect in March 2024, included measures to ensure that both new vendor and annual reviews are documented. The Accounts Payable department will continue to conduct suspension and debarment reviews for all new vendors before conducting business and perform annual reviews of all vendors, in line with the FY23 Corrective Action Plan. Anticipated completion date: Completed March 2024.

Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.

Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 29, 2026 A material weakness was issued related to internal control over suppliers under the UG audit. CFNI recognizes the need to comply with the procurement standards outlined in 2 CFR §§ 200.318-326, which require written policies addressing competition, conflicts of interest, procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurement), oversight, efforts to engage small and disadvantaged businesses, and procurement of recovered materials, among others. To address this deficiency, CFNI is committed to enhancing its documented procurement policies for procure-to-pay processes involving federal funds. The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists—periodic PeopleSoft program checks and an annual review by a third-party vendor—no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors. CFNI will develop and implement a robust supplier management policy, incorporating requirements for procurement, suspension, and debarment reviews. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements. The Problem: During testing the auditors noted that one instance of purchasing using WSDA funds was made without WSDA prior approval and proper documentation of suspension and debarment or WSDA prior approval. Established Standard: Organization must verify SAM registration and conduct suspension, and debarment checks prior to entering into any sub-agency agreement, contract, purchase, or equipment repair over $5,000. It is recommended that lead agency verifies, at least annually, that sub agencies and vendors are not suspended or debarred. Information about suspension and debarment checks is to be entered onto a spreadsheet of approved vendors. When the lead agency enters into a covered transaction with another agency or vendor, lead agency must verify that the entity with whom business is transacted is registered with SAM and is not excluded or disqualified. There are two methods for verification: A. Checking SAM.GOV exclusions (this method requires saving a copy of the verification search) B. Collecting a signed certification from the vendor. Actions to be taken: • Updated training of TCFB staff on the Policy/Procedures for procurements using WSDA funding. • Create step-by-step instructions for purchases using WSDA funding. • Effective October 1, 2024 WSDA’s threshold for preapprovals changed to $10,000. We will update our purchasing policy to reflect this change. Action Assignments: • Instruction checklist will be created by lead purchaser. • Lead purchaser will ensure that any purchases follow the Policy/Procedures for procurement. • Lead purchaser will be responsible for documenting SAM registration, Suspension and Debarment check, and WSDA pre-approvals. The documentation will consist of a copy of the exclusions page on SAM.GOV, as well as a spreadsheet of approved vendors with a date of last check. Timeline: • Instruction checklist for purchases using WSDA funds will be created by July 1st, 2025. • A spreadsheet has already been created to capture the information concerning Suspension and Debarment checks. A separate folder contains copies of each entities exclusion page from SAM.GOV. Verify Implementation: • In July 2025 Lead Purchaser will submit to the Executive Director: A. A copy of step-by-step instruction checklist. B. A copy of the spreadsheet with Suspension and Debarment checks C. Copies of exclusion pages from SAM.GOV Finance Dept. will verify invoice have received WSDA prior Approvals

2024-03: Lack of Procurement Policy Contact Person Heather Ferebee Corrective Action Plan A procurement policy will be developed and approved by the City Council. Completion Date 2025

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Moving forward, the district will perform a cost/price analysis for procurement in excess of $250,000.

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process The district has also since enrolled with Bonefish, a partner of OASBO and Ohio Schools Council (OSC) to satisfy all requirements of securing vendors/entities using the Federal government’s System for Award Management (SAM). This will create the proper internal controls that were lacking.

Corrective Action Plan Actions Planned – The City will hold pre-meetings with grant administrators to ensure all federal compliance requirements are met including verifying suspension and debarment. Official Responsible – Amy Sevig, Deputy Finance Manager Planned Completion Date – December 31, 2025 Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – Janet Burns, Grant Coordinator Accountant, will oversee the process to ensure pre-meetings are set up with grant administrators and the City is in compliance with all federal grant requirements.

Finding: The Foundation is responsible for implementing policies, including internal controls, that are designed to provide reasonable assurance regarding the achievement of the following objectives: effectiveness and efficiency of operations, reliability of reporting for internal and external use; and compliance with applicable laws and regulations. During the audit, it was identified that the federal procurement and other policies surrounding federal funds, as required under the Uniform Guidance (2 CFR Part 200), were not fully implemented until the latter part of the year. Consequently, certain procedures conducted prior to the implementation of the new policies did not incorporate all required federal standards. Corrective Action Taken: Management, under the leadership of the Chief Executive Officer, Josh Goldberg, has developed and fully implemented a comprehensive procurement policy compliant with federal regulations under the Uniform Guidance (2 CFR Part 200) starting October 2024. This policy ensures adherence to all required federal standards, including competitive bidding, vendor selection, conflict of interest, and documentation requirements. Staff have been thoroughly trained on the new procedures to ensure consistent application across the organization. Internal monitoring controls are in place to ensure ongoing compliance for all federally funded procurements. Management also maintains active communication with awarding agencies to ensure a clear understanding and proper implementation of all compliance requirements related to federal funds. Completion Date: January 1, 2025

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained. Corrective Actions Taken or Planned MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions: Policy and Procedure Update As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file. Procurement Checklist Enhancement Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented. Training Implementation All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications. Ongoing Monitoring A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained. Contact Person Responsible Tariq Bahich Senior Director Finance Anticipated Completion Date Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.

2024-001 Procurement Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Congressionally Directed Spending Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable In accordance with 2 CFR 200.318 the System must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. For two of two of the auditors’ selections sufficient documentation was not retained from the time of procurement during fiscal year 2023 to demonstrate sole source justification or the competitive bidding process for these samples. For one mammography technology asset, documentation of sole source vendor justification was not documented and retained by the System following Policy HA-50-42, Capital Equipment Requests. For the second selection, while competitive bids were obtained, management did not adequately retain documentation to support the vendor ultimately selected for the selected hardware component and the other bids obtained. Management has reviewed the Capital Equipment Request policy and the related capital request process and will reinforce the need to adhere to existing policies and the importance of retaining appropriate documentation during fiscal year 2025. Primary responsibility of implementing the Corrective Action Plan for this finding rests with Brian Huggins, Senior Vice President of Finance, Corporate Controller, (508) 334-0252.

U.S. Department of the Treasury AUDIT FINDINGS: Finding Reference Number: 2024-001 Description of Finding: Family Centered Services of CT, Inc. had not updated its procurement policy to conform to requirements in accordance with the Uniform Guidance. The policy in effect during fiscal 2024 did not specify a micro-purchase or small purchase threshold above which written quotes would be required. Additionally, a written policy for ensuring vendors are not suspended or debarred was not included in the existing policy and therefore this process was not being executed in a consistent manner. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new Uniform Guidance-compliant procurement policy, including a process to ensure vendors are not debarred, was prepared and implemented in January 2025. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed, Name of Contact Person: Jacquelyn Farrell, LCSW Executive Director 203-624-2600x204 jfarrell@familyct.org Projected Completion Date: Immediately

Management agrees with the finding. The City will implement procedures to ensure all purchases over $15,000 are formally approved by the City Council and are documented in the minutes.

May 27, 2025 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Re: Corrective Action Plan Regarding Section III: Schedule of Findings and Questioned Costs for the Fiscal Year Ended September 30, 2024, in Reference to 2024-001 Procurement It was identified in the findings of 2024-001 Procurement (repeat comment) that LCCMH had not followed proper procurement requirements and procedures regarding the agreement in reference to ALN 93.969 Certified Community Behavioral Health Clinics (CCBHC) expansion Grants. LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Thank you, Brooke Sankiewicz Chief Executive Officer Lapeer County Community Mental Health (810) 667-0500 bsankiewicz lapeercmh.org

Finding 2024-004 Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Lincoln’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management is working with our current auditors to update the Town’s procurement policies to be in compliance with Uniform Guidance. Name of Contact Person John Cimino, Finance Director Projected Completion Date 6/30/2026

The American Immunization Registry Association (AIRA) respectfully submits the following corrective action plan for the year ending September 30, 2024. Independent public accounting firm: HAN GROUP, LLC, Washington, DC Audit period: Year ending September 30, 2024 The finding from the year ending September 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2024-001 – Procurement, Suspension and Debarment. Audit Recommendation – Strengthen internal controls over procurement documentation by: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. Management Response – AIRA acknowledges the finding and will implement the following: 1. Procurement Checklist: A standardized procurement checklist will be developed and required for all federally funded procurements. This checklist will help ensure consistent documentation practices and that all necessary procurement steps and compliance elements are completed and retained. Documentation of the completed checklist will be retained in the procurement file. 2. Vendor Eligibility Verification: A formal review process will be established to verify and document vendor eligibility through SAM.gov before awarding any contracts funded with federal funds. Documentation of the eligibility check will be retained in the procurement file. 3. Staff Training: Targeted training sessions will be conducted on a recurring basis for all staff involved in the procurement process. These trainings will reinforce federal compliance requirements, including proper documentation practices and suspension/debarment verification. Training completion will be tracked and documented. Implementation Timeline – As of March 18, 2025, AIRA has implemented a verification of vendor eligibility process using SAM.gov. The procurement checklist will be developed and implemented by April 30, 2025, and regular trainings will commence by May 31, 2025. We are committed to ensuring full compliance with federal procurement requirements. Please contact the Business and Operations Director at 202-552-0208 with any questions.