The Gavin Foundation, Inc.

Finding No. 2024-001 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Congressional Directives Assistance Listing Number: 93.493 Federal Award Identification Number and Year: 6 CE1HS46475-01-05 (2023) Criteria Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. Condition The Agency did not maintain contract files that documented the history of procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection and basis for the contract price. Cause The Agency performed procurement procedures, including soliciting bids/proposals from multiple contractors, evaluating them and selecting the contractor based on their procurement procedures. However, as the project was completed they maintained the contracts related to the contractor selected but inadvertently disposed of the documentation related to the procurement process. Effect or Potential Effect The procedures for procurement were not consistently applied in accordance with 2 CFR sections 200.318 through 200.327. Question Costs None noted Context For 1 of the 2 procurements sampled, the contract file did not include documentation of the history of the procurement. The total population the sample was selected from was 7. Identification as a Repeat Finding N/A - not a repeat finding Recommendation Management should establish procedures and controls to ensure contract files include the history of procurement and the documentation is maintained. Views of Responsible Officials Management agrees with the finding and has updated its procedures and controls to ensure procurement history is adequately documented and maintained in the contract files.

CORRECTIVE ACTION PLAN March 17, 2025 Health Resources and Services Administration 5600 Fishers Lane Rockville, MD 20857 The Gavin Foundation, Inc. respectively submits the following corrective action plan for the year ended June 30, 2024. CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit Period: June 30, 2024 The finding from the June 30, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-001 Congressional Directives - Assistance Listing No. 93.493 SIGNIFICANT DEFICIENCY Recommendation Management should establish procedures to ensure contract files include the history of procurements and the documentation is maintained. Action Taken The organization performed procurement procedures, including soliciting bids/proposals from multiple contractors, evaluating them and selecting the contractor based on their procurement procedures. However, as the project was completed we maintained the contracts related to the contractor selected but inadvertently disposed of the documentation related to the procurement process. We have met with employees responsible for completion and filing of the procurement documentation and discussed the importance of not only completing the documentation, but also the importance of its proper filing. We have updated our procedures to ensure procurement history is adequately documented and maintained in the contract files. These actions were implemented (or are anticipated to be implemented) effective March 17, 2025. If the Health Resources and Services Administration has questions regarding this plan, please call Peter Barbuto at (857) 496-7341. Sincerely yours, Peter Barbuto, CEO The Gavin Foundation, Inc.