Corrective action taken On June 2, 2025, the Board approved revised Policy F2.01 v.01, Procurement for Product or Services, which requires competitive proposals for contracted services, documented selection criteria, and retention of bid responses and award decisions. Effective September 1, 2026, C-WHO adopted Procedure SOP F2.01 v.01, Procurement Under Federal Awards, approved by the Chief Executive Officer and the Director of Finance. The procedure supplements Policy F2.01 v.01 and applies to any purchase charged in whole or in part to a federal award. SOP F2.01 v.01: • incorporates 2 CFR 200.317 through 200.327 and Appendix II to Part 200, as adopted by HHS at 2 CFR Part 300; • sets procurement methods by the current federal thresholds (micro-purchase, small purchase with at least three written quotes, and sealed bids or publicized proposals above the simplified acquisition threshold); • limits noncompetitive procurement to the circumstances in 2 CFR 200.320(c), documented on a Sole Source Justification form approved before commitment; • requires SAM.gov exclusion verification before any covered transaction of $25,000 or more (2 CFR Part 180), and an LEIE check for health care service providers; • establishes written conflict-of-interest standards, including disclosure, recusal, and disinterested Board approval for related-party procurements; • requires cost or price analysis above the simplified acquisition threshold and documented price reasonableness for all federally funded purchases; • requires a Federal Procurement Checklist, completed by a preparer and signed by a separate reviewer, before a contract is signed, a purchase order is issued, or federal funds are charged; and • credits discounts and rebates on federally funded purchases to the award under 2 CFR 200.406.