Legal Services Corporation Grant – Assistance Listing No. 09.436183 Recommendation: We recommend that the Organization update its procurement and vendor approval procedures to require documented suspension and debarment verification prior to entering into covered transactions, in accordance with 2 CFR §§ 180.300 and 180.320. Documentation of the verification should be retained in the procurement or contract file to demonstrate compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. During 2025, periodic suspension and debarment reviews were performed; however, the process did not require verification prior to entering into covered transactions. Management will revise its procurement policies and procedures to require suspension and debarment verification before execution of covered contracts, including contracts funded with LSC or other federal funds that are expected to equal or exceed $25,000, contracts requiring LSC or federal approval, and other covered transactions. Documentation of the verification will be retained with the procurement file and must be dated prior to contract execution. Corrective Action: Effective immediately, LAWO will require a SAM.gov Exclusions search, vendor certification, or suspension/debarment clause before entering into covered transactions. The preferred method will be a SAM.gov Exclusions search. Procurement policies and procedures will be updated to include this required step. The staff member responsible will retain the dated verification in the procurement file. Name(s) of the contact person(s) responsible for implementing corrective action: Scot Henshaw, Manager of Business Operations Planned completion date for corrective action plan: July 1, 2026