Corrective action planned – Management recognizes that procurement is a material concern of the organization both from an operational efficiency and regulatory compliance perspective. During the audited time period, procurement responsibilities were decentralized, resulting in inconsistent compliance. In April 2025, Management decided to create a dedicated Procurement Department and began staffing the department. The new Procurement team is tasked with reviewing all current procurement policies and procedures, revising and creating new processes as needed, and partnering with the compliance team to monitor compliance going forward. The policy and procedure revisions will be implemented by the end of the fourth quarter of 2025. Staff will receive training by the first quarter of 2026, and after the training rollout, we will begin internal audits to ensure successful training, implementation and compliance with the new policies and procedures. The recently created Procurement Department will begin documenting and retaining evidence that vendors are not suspended or debarred for all projects funded by federal awards. Name(s) of contact person(s) responsible for corrective action – Alison Spens, Senior Director of Project Management and Procurement Anticipated completion date – August 15, 2025