Town’s Response: The Town concurs with the audit finding and has begun implementing the corrective actions outlined below. 1. Policy Alignment o Revise the Town’s Procurement Policy to explicitly state that federal Uniform Guidance procurement standards supersede state exemptions when federal funds are used. 2. Procedural Controls o Require a funding source review step in the requisition process: if any portion of funding is federal, staff must apply federal standards. o Incorporate a mandatory compliance checklist for all federally funded procurements, including documentation of cost/price analysis, vendor selection, and conflict of interest certifications. 3. Training & Awareness o Conduct annual training for the Procurement Manager. o Provide written desk guides / “quick reference sheets” for federal vs. state thresholds and documentation requirements. 4. Oversight & Monitoring o Director of Finance/Assistant Finance Director to review and approve all federal-funded procurement files prior to award. o Establish quarterly compliance monitoring of federal procurements, with results reported to the Town Manager via Monthly reports submitted. 5. System Enhancements o Explore Munis configuration options to flag federally funded accounts during requisition entry, ensuring the correct rules are applied. 566 Washington Street, P.O. Box 40, Norwood, MA 02062-0040 Phone No. (781) 762-1240 Responsible Parties: Procurement Manager – day-to-day compliance Completion Date: Policy revision and training to be completed by December 31, 2025. Compliance checklist implementation and monitoring effective immediately for all new procurements using federal funds. Submitted By: Jeffrey O’Neill Director of Finance & Town Accountant