Finding Summary: NNCH did not properly procure three contracts in accordance with applicable procurement requirements and the Organization's procurement policy. Additionally, procedures were not sufficient to ensure that contracts contained all provisions required under Uniform Guidance. Responsible Individuals: Matthew Fleming, Executive Director; Jocelyn Kendall-Perez, Deputy Director & CFO Corrective Action Plan: Management acknowledges the finding and has reviewed the circumstances surrounding the contracts identified with the independent auditors. Two of the three contracts identified involved specialized professional services, including a development consultant whose engagement originated prior to NNCH's receipt of the applicable federal funding and a procurement management consultant. Although management considered the specialized nature and circumstances of these engagements when making the contracting decisions, NNCH recognizes that the procurement documentation maintained did not sufficiently demonstrate compliance with the applicable federal procurement requirements. As part of management's review of this finding with the independent auditors, NNCH discussed adopting a more conservative procurement approach for future contracting. Going forward, NNCH intends to evaluate and document procurements with the expectation that federal funding requirements may ultimately apply, even when federal funding is not anticipated at the time the contract is initiated. This approach is intended to provide greater flexibility if a funding source changes during the term of an engagement and to reduce the risk of an existing contract later being determined ineligible for federal reimbursement due to procurement requirements. NNCH will update its procurement procedures and develop a standardized procurement checklist addressing applicable procurement thresholds, required competition, documentation of permissible noncompetitive procurement when applicable, required approvals, suspension and debarment verification, and applicable federal contract provisions. Procurement documentation will be maintained with the applicable contract or project records. NNCH will also review applicable contracts prior to execution to verify that required procurement documentation and contract provisions have been addressed. Staff involved in contracting and procurement will receive guidance regarding the revised procedures and documentation requirements. Anticipated Completion Date: December 31, 2026