The Trustees of Reservations and Affiliates

Federal Agency: Department of the Interior Federal Program Name: Boston Harbor Islands Partnership - World's End Carriage Road Restoration Assistance Listing Number: 15.947 Federal Award Identification Number and Year: N/A Pass-Through Agency: National Park Service Pass-Through Number(s): P24AC02282 - 2023 Award Period: 10/01/2023 – 09/30/2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: Procurement methods used must be in compliance with conditions specified in 2 CFR section 200.320. Condition: For the acquisition of small purchases of which the aggregate dollar amount is higher than the micro-purchase threshold ($10,000) but does not exceed the simplified acquisition threshold ($250,000), price or rate quotations must be obtained from an adequate number of qualified sources. Questioned costs: None. Context: Documentation over price or rate quotations was not maintained for 2 (of 5) testing selections. Cause: Documentation over price or rate quotations was not maintained, which prohibited the auditors from successfully perform testing over these transactions. Effect: Noncompliance with Uniform Guidance procurement requirements. Repeat Finding: N/A. Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micro-purchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Views of responsible officials: There is no disagreement with the audit finding.

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend documentation over price or rate quotations be maintained for all vendors with procurements that could potentially exceed the micropurchase threshold ($10,000), rather than only those with an original purchase price exceeding $10,000, as the procurement policy is currently written. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Small Purchase Procurement: We have enhanced document retention procedures around small purchase procurement including staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure a minimum of 3 bids/quotes are obtained on any grant-funded purchases or services greater than $10k. We will be utilizing NetSuite's Document Library to manage document retention for grant-related bids and quotes. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

Federal Agency: Department of the Interior Federal Program Name: Boston Harbor Islands Partnership - World's End Carriage Road Restoration Assistance Listing Number: 15.947 Federal Award Identification Number and Year: N/A Pass-Through Agency: National Park Service Pass-Through Number(s): P24AC02282 - 2023 Award Period: 10/01/2023 - 09/30/2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 2 (of 2) selections tested. Entire population was tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Views of responsible officials: There is no disagreement with the audit finding.

Department of Interior Boston Harbor Islands Partnership – World’s End Carriage Road Restoration Assistance Listing No. 15.947 Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Suspension/Debarment: We have enhanced our written policies and document retention procedures around suspension/debarment checks, including comprehensive grant kick-off staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure debarment checks are completed prior to procurement. We are also exploring a custom integration with NetSuite's SuiteScript and SAM.gov Exclusions API to continually monitor vendor eligibility. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253

Federal Agency: Department of the Interior Federal Program Save Americas Treasures Assistance Listing Number: 15.929 Federal Award Identification Number and Year: N/A Pass-Through Agency: National Park Service Pass-Through Number(s): P22AP02229 - 2022 Award Period: 10/01/2022 - 09/30/2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matter Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Verification that vendor was not suspended/debarred from receiving federal funds was not performed prior to procurement, as required for compliance with 2 CFR section 180. Questioned costs: None. Context: Management was not aware of the requirement resulting in noncompliance in 1 (of 1) selections tested. Entire population was tested. Cause: Management was not aware of the requirement at the time of procurement. Effect: Increased risk of contracting with vendors who are suspended or debarred from receiving federal funds. Repeat Finding: N/A. Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Views of responsible officials: There is no disagreement with the audit finding.

Department of Interior Save Americas Treasures Assistance Listing No. 15.929 Recommendation: We recommend the procurement policy be amended to include language that would require compliance with Uniform Guidance suspension/debarment requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Suspension/Debarment: We have enhanced our written policies and document retention procedures around suspension/debarment checks, including comprehensive grant kick-off staff training by the Grants and Restricted Funds Manager and a new pre-award check-list to ensure debarment checks are completed prior to procurement. We are also exploring a custom integration with NetSuite's SuiteScript and SAM.gov Exclusions API to continually monitor vendor eligibility. Name(s) of the contact person(s) responsible for corrective action: Brian Therrien, Chief Financial Officer, 617-456-5253