Management acknowledges that procurement documentation was not consistently maintained during the audit period. Because the FY2024 audit was completed after the FY2025 fiscal year had ended, management did not have an opportunity to implement the prior-year corrective actions in time to affect the FY2025 audit period. Since the audit period, the Organization has strengthened procurement and compliance oversight by elevating the Director of Programs position to Vice President of Programs in September 2025, launching the Compliance and Risk Management Committee in FY2026, and creating a Compliance & Evaluation Manager position with an anticipated start date in August 2026. Fiscal and program leadership have substantially revised the procurement policy and are developing related procedures and standardized documentation requirements. The policy and procedures will be reviewed by the Compliance and Risk Management Committee in early FY2027 before being submitted for Board approval. The revised materials address competitive quotations and bids, vendor selection, price reasonableness, noncompetitive procurement justifications, conflict-of-interest requirements, debarment verification, and documentation of the procurement history. The FY2027 budget includes 2 CFR Part 200 training for Fiscal, Programs, and Grants staff. Blackbaud Financial Edge, scheduled to go live in FY2027, will further support approval workflows, transaction tracking, role-based access, and document retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken • Elevated the Director of Programs position to Vice President of Programs in September 2025. • Launched the Compliance and Risk Management Committee in FY2026. • Created a Compliance & Evaluation Manager position, with an anticipated start date in August 2026. • Strengthened supervisory review and reinforced procurement documentation expectations. • Substantially revised the procurement policy and began developing standardized procedures and documentation requirements. • Scheduled Compliance and Risk Management Committee review of the revised policy and procedures for the fall of 2026. • Included 2 CFR Part 200 training for Fiscal, Programs, and Grants staff in the FY2027 budget. • Initiated implementation of Blackbaud Financial Edge; planned go-live for October 2026.