Corrective Action Plan:
1. Policy and Procedure Update:
GWA's procurement procedures have been revised to include a mandatory SAM.gov exclusion
check prior to awarding any contract or subcontract funded by federal assistance. This
requirement has been incorporated into the standard procurement checklist and contract file
documentation process. Additionally, all related Standard Operating Procedures (SOPs) will be
updated by December 2025.
2. Training:
GWA will conduct training for procurement, project management, and finance personnel on
federal compliance requirements, including procedures for verifying suspension and debarment
status. Training will be completed by December 31, 2025, and as needed as staff turnover or
new regulations are issued.
3. Documentation Requirement:
Staff are now required to print and retain a copy of the SAM.gov search results in the
procurement file as documentation that the contractor is not debarred or suspended at the
time of award.
4. Ongoing Compliance Monitoring:
The Internal Audit team will conduct periodic reviews of federally funded procurement files to
ensure compliance with this requirement and to verify that proper documentation is
maintained.
Expected Completion Date: Procedures were put in place on April 4, 2025. Updates to all relevant SOPs
as well as training will be completed by December 2025.
Point of Contact for Follow-Up:
Prudencio F. Aguon, Grants Administrator
Janet L. Taitano-Arroyo, Internal Auditor