Date: August 6, 2025
Transcript: Good Governance: Fiscal Oversight for IL Leaders, Cohort 2, Session 2

TYLER: Good to see some familiar names from last week's session. All right. We will go ahead and get started. Welcome, everyone to our second week in our fiscal oversight for IL leaders. Today, we will be talking about our best practices for procurement. My name is Tyler Morris, the director of training at the independent living training and technical assistance center. We are going to go ahead by having a couple of accessibility notes for review we have ASL in Spanish interpreters available in labeled for you. You can access them and closed captioning by using the icons at the bottom of your zoom window. Since this is a cohort, we had conversation throughout with questions, be mindful either raising your hand or drop your question in chat for Paula McElwee or John Heveron. Since we are using our interpreters captioning today, the state your name before speaking. Our team is labeled in the chat if you experience any accessibility issues or need any assistance throughout today's training, please reach out to us to the chat feature and as always, your feedback is very important to us so we will have a survey for you to complete at the end of this training. And hope you will take time to go ahead and fill that out. Let's set the stage for today on our learning objectives. What we will learn today are what requirements you must follow and document for procurement purchasing with federal funds. How to determine whether your procurement policy is compliant. What procurement thresholds are currently in effect and how to find updates. Lastly, what are the conflict of interest requirements are for procurement. With that said, I am going to introduce today's speakers, Paula McElwee and John Heveron are here to share a wealth of information. So please join me in welcoming them and I will pass it over to you both. Thank you all. 

PAULA: John Heveron and I have been doing this for a little while we mentioned that I think last time how long and it was earlier than when I got into IL I thought I was there close to the beginning so when they' 70s, folks. Been doing this a while and financial stuff is pretty solid, clean, clear we just need to communicate to you. I'm the director of technical assistance for the IL T&TA center I will let John Heveron introduce himself and little bit more is a consultant and a CPA that works for us in this area. 

JOHN: I am a semi-retired CPA but have been in the business since I started with Ernst and Ernst in 1969, I started my business in 1972. When a my business I'm not an owner anymore the younger partners on it but I work here part‑time, and this is part of what I do and enjoy. It's been a long haul, and I continue to enjoy. 

PAULA: We appreciate the way you help communicate these important principles. Tyler, next slide, please. We are going to talk about procurement and we put this in the statements, that is the term used in the regulations we are talking about purchasing, how you purchase things and how you do it in a way that is going to make sure that you follow the requirements because you receive federal money you have specific strings attached that money, you have things you have to do in order to make sure you follow the requirements. We put in red the first of those that is to make sure that everything you purchase is " reasonable and necessary ". You put this in a written policy you are required to have a procurement policy have a sample policy on our website with the resources for this presentation you can take and make fit your organization, but you need that policy and you need to start with reasonable and necessary. John Heveron? 

JOHN: Thanks, Paul. Just to add on, it's been a requirement to have a procurement policy for spending federal funds for a while. The most recent updates to Uniform Guidance made it clear it has to be in writing. I don't know how you could not have it in writing before and have it be successful. At any rate, in no uncertain terms, it has to be in writing. If you are here to tune up your policy, it is fantastic. If you don't have a written policy, glad to have you here and hopefully, this will help. In addition to limiting purchases to reasonable and necessary items, we want to minimize the possibility of theft or misuse and there are specific procedures that will be discussed. We want to control costs and ensure high quality we need to comply with general federal and HHS specific and ACL regulations. Identify the nature and program or supporting service of the purchase. This was last week's presentation, but I will say, do that right at the time you make the expenditure. In other words, when you are spending funds identified program or supporting service that will benefit from that. 

PAULA: I might mention related to that we had somebody undergoing review just last week. They said, do I really have to put on the receipt which programs benefit from that expenditure?” You have got to put it somewhere. On the receipt is 1 place, and your books is one place, but you have to identify at the time you make the purchase what program it's going to you don't get to decide later. It has to be part of your plan you have to know all your expenses. We talked about some of this last week because we talked about how you identify direct and indirect expenses but don't forget that piece it's an important one. This particular center was struggling. That is not how it is supposed to work. 

JOHN: Absolutely. 

PAULA: Next slide. 

JOHN: The key areas of the procurement policy identifying who is responsible for purchasing it may be a single individual in your organization or depending on the size of your organization there may be multiple people that would approve at different levels or for different programs. That is key. Comply with uniform guidance and HHS regulations these include purchasing only items necessary for the performance of the award and where appropriate, analyzing lease versus purchase options. We are going to talk about that more later. Also documenting the basis for contractor selection if you are doing construction contracts. As we said a bit ago, needs to be in writing. If we can move on to the next slide. Key areas of the program include having specific procedures about conflicts of interest and we will talk about those. Maintaining a whistleblower protection policy. Employees will cover most errors, I read this but last night I re‑looked at the Association of certified fraud examiners report to the nation's, it is the ACFE report it says tips cover ‑‑ tips uncover the majority of frauds. It is also three times as many as any other method of uncovering. As an auditor I love to hear audits uncover the majority, but tips uncover the majority and employees provide over 50% of the tips. A whistleblower protection policy is really valuable to your organization. You need to have employees feel comfortable if they feel something is done, comfortable reporting it. Another component is competitive proposals must follow your process. We can go on to the next slide. We have got different levels the names of the levels don't change but the levels themselves do change periodically. Right now, the micro purchase level the smallest level, is purchases up to $10,000. We don't have significant requirements when it comes to micro purchases, the only guidance we really have is we should consider using different vendors, different suppliers for micro purchases. 

PAULA: A word if I might about this. This $10,000 level is not effective for part C until September 30th because you are working in a different fiscal year, but this is the new regulation and if you are going to update your policy make it effective September 30th it will cover this 10,000-dollar amount. Many of you have policies that require internal approvals at a lower level than this 10,000 dollars. That is okay, you are allowed to do that, also your state if you are getting state funding part B funding comes through your state and your state may have requirements at a lower level. But the feds consider purchases individual purchases of 10,000 dollars or less to be the smallest purchase that you can make. We'll talk about equipment in a minute they haven't changed in another place were equipment shows up so it's a little different level. This is kind of a surprise to a lot of people. That seems like a lot of money and a lot of you are getting bids at a lower level. You have the right to do that, your own policies can require that but it's not required on the federal level. The federal acquisition level threshold for not having to get price comparisons or anything is 10,000 dollars. 

JOHN: It is also important to remember if your policy calls for a lower amount, say, 4000 dollars you need to comply with that it will be noncompliance if you don't comply with your own policy even if you are within the federal threshold. That is something to consider and you may even want to increase the amount of your policy, unless you feel it's important to keep it at a lower level. There are different definitions the micro purchase threshold for different sets of circumstances. When I looked last night, I don't think they generally apply, one is for public buildings, one is for services for the federal government the third one down is if there is possibly a contingency operation recovering from a cyber attack might be the only one that might apply to that would still be a micro purchase at a higher level. On the next slide there is one more of these. It's not probably going to be applicable to any of you because it is intended for institutes of higher education. We can probably move right to slide 10. In slide 10 is called the simplified acquisition threshold. This is sort of the middle ground between the micro purchases and larger categories of purchases. At this point in time is generally up to $250,000, so above 10,000 and not to exceed $250,000. Again, we cited a couple of other things that meet the definition of simplified acquisition threshold. I don't think you are going to find them applicable to you. 

PAULA: We just wanted to include them for a reference if you are making purchases at this level. What we find is very seldom is a center making any kind of acquisition at this level. Most of the time, it is 10,000 and under and once in a while it will go over but not very often anymore unless you’re purchasing a building or making some major modifications to our building. You are typically not spending $10,000 more for most of your purchases. These higher-level acquisitions don't happen very frequently. When they do happen, These Refer the written regulations to make sure you know which category you fall under if you have those higher acquisitions that they don't happen often. 

JOHN: Agreed. Yet, you want to have them in your policy so that is important. The slide 11 is sort of an outlier, something that doesn't apply to any of our organizations they are talking about humanitarian or peacekeeping operations not that we don't need a little peace these days I don't think it is part of our programs. 

PAULA: Not part of our purchasing policies. 

JOHN:  Right. Slide 12 as we said your board may set lower limits for approval or set multiple limits or you may need a different person to approve or a second approval. Also, state funds may have a lower limit. Paula McElwee, I would appreciate your input but I don't think the lower limits for state contracts would be applied to federal contracts, in other words you would write your procurement policy to say for state funds we would use these lower thresholds. 

PAULA: The state does pass those two-part B sometimes and it applies to the actual purchases made with state dollars which many centers also have. There may be a lower level. A lot of states have adjusted these upward with the new regulations. Do check back with your state because you may be operating under the assumption, they are requiring approval or bids and $1,000 and they have already changed it to 10,000 or 5000 so do look at that. The state will set it sometimes. 

JOHN: Thank you. The next slide. These dollar limits are adjusted periodically for inflation it's been a little inconsistent in the past, but the regulations say that the FAR counsel will periodically adjust all of these threshold with the FAR counsel is, is the Federal Acquisition Regulations. The adjustments go through this FAR counsel and will apply to not only for profit but nonprofit. It is calculated every five years it started back in on over 2005 uses the consumer price index, a version of it. Based on that, it is highly likely we will have an adjustment in October 2025 right around the corner. I've read speculation about what the amounts will be but we are going to have to wait and see if that becomes an issue. Paula, I am sure we can get that out within a reasonable time once it is updated and approved by HHS. 

PAULA: We will make sure we let you know if these thresholds change but make sure your policy matches these. Remember, HHS Health and Human Services which is where ACL office of independent living programs, our centers are funded through that, have not yet accepted the uniform guidance, they accepted it October 1st of 2024, but your part C funding is from that prior fiscal year. You can't have those higher levels effective until you receive part C funds until September 30th, but we figure that is just around the corner. If they change again, we will let you know you can make those changes. Here are places where you can find that information if you want to look it up there is a reference here to the regulation of how that works, and we have the OMB memo which includes that current information is listed for your use. Let's look at that next slide there's another interesting thing I want to talk to you about, that is equipment purchases. All of this is true with most of your purchasing, right? In the regulations at this moment the requirement is that equipment purchases are any piece of equipment that you purchased the has a value of 5000 dollars or more. We don't do a lot of that kind of purchasing, vehicles would fall there if your purchasing a vehicle is going to fall under this equipment purchase requirement. ACL, has given us a form they want you to complete for equipment purchases and that is posted with this presentation in the resources you will find. Equipment is any tangible personal property that might include computers although few are worth 5000 dollars, servers of course, a lot of photocopying machines if you purchase those would fall there are you do a lease, purchase and vehicles. You want to fill out this request. You need prior approval for that purchase. You don't get to do it because it is under 10,000 dollars without going through a bid process, et cetera You have to have a separate kind of approval for any equipment purchase it also needs to go into your inventory, and you need to keep an inventory of equipment. I often suggest to you, you also keep an inventory of anything you want to keep track of. Do you have to keep an inventory of iPads, no because they cost under 5000 dollars but I would suggest yes they are easily transported piece of valuable, valued equipment even though it's not equipment technically because it is under 5000. I recommend you keep an inventory of not just those things with 5000 or more but other things as well. I think you will find your state and federal reviewers want to see you know what you did with things you purchase. They are going to likely want that for any IT whether or not it costs 5000 dollars. We recommend you keep an inventory so you can tell people. We had a center reviewed recently during COVID they purchased iPads for communication for people when they were reviewed, they could not tell anybody where the were, you can lease or loan those things from your inventory and if they disappear, you have to say they disappeared, we gave it to person X and they no longer have it. You have to be able to say where it was you can't just hand things out. I don't know how else to say it, John, does that make sense? 

JOHN:  It does to me. 

PAULA: Those are special requirements different from the other requirements the other regulations we are going to are in a different place in this shows up just about equipment. It's like this little capsule tucked in there requires a special form and inventory as you make this purchase. Next slide. 

JOHN: The final bullet says equipment can only be used for the grants programs and as you mentioned must be inventoried and disposed of properly, disposed of properly doesn't mean you are disposing of it necessarily. It probably wasn't the best term we could have put in there. In may be required to be used for another federal program, it may be required to be returned you may be able to use it without further restriction. You need to follow up with that and find out what the requirements are. 

PAULA: Often you can use it in another federal program if you no longer need it and also, we've had centers that have closed and passed the property on as part of their closure process to other centers in their state. We see different ‑‑ and if it's no longer operational you Mark it is disposed of if you don't want to use the term it's removed from inventory and why. It is depreciated out and no longer in operation. It's been destroyed whatever the reason is. 

JOHN: The next slide. The larger purchases over that simplified acquisition threshold get divided into 2 categories, sealed bid proposals and competitive proposal purchases both over that dollar amount of currently $250,000. There is noncompetitive procurement which can only be used in certain cases. For example, when there is only a single source, where there is an emergency or other reason for noncompetitive proposal and we have provided a reference with that. 

PAULA: That would be an exception to the rule. 

JOHN: Yup. Next slide. For sealed bid proposals, over that $250,000 threshold request proposals publicized the request identify all criteria the evaluation is going to be based on, publicize this in trade publications, newspapers, government websites. I'm not sure how to do that you may know. 

PAULA: No, and I will find out. 

JOHN: You should reach out to an adequate number of qualified sources to ensure transparency and fairness and a fair price to you. Provide an equal opportunity to bid in a written procedures for evaluating and selecting recipients and those who should be specified in the invitation to bid in the award would be made to the lowest responsive and responsible bidder who can perform the contract. Price is a major factor but not the only factor. 

PAULA: When reviewing competitive or sealed bids, when they come into your and you use your evaluation criteria you may find the low bid does not meet all the criteria you don't have to take that low bid. If they are not able to do the contract as specified in your specifications. You have to document why not but you don't have to use them. 
JOHN: Next slide. Price rate quotation should be solicited from an adequate number of qualified sources. I would say not less than three I don't know whether you have any thoughts on that. 

PAULA: That is what we recommend. Two might be appropriate if there aren't other qualified providers of that service or that item. But that is unusual, most of the time when you spend this amount of money you can find three bids. 

JOHN: Here, we put a little different spin rather than saying the best price we say it should be awarded to the responsible supplier whose proposal is most advantageous to the program. That does include price but also includes other qualitative requirements. There should be a statement in the vendor contracts they have not been suspended or debarred from doing business with any federal agency. You can also check that Sam.gov ‑‑ 

PAULA: I recommend you check it yourself when reviewing these bids. You can do that by going to Sam.gov searching for these providers. Also ask them in their proposal to verify that. Their proposal includes a statement from them that says they have not been disbarred from doing business with any federal agency. Because you spent federal money you have to meet those federal requirements. 

JOHN: Next slide. As Paula pointed out, it is going to be a rare we are going to do these large purchases, but you still need to have this in your policy. You may not get as elaborate with this part if it is not likely to happen or won't happen often, but you do need to provide for these, and it needs to be in your written policy. Your policy should identify the limited exceptions to competitive bidding where there is only a single source where there is an emergency or urgent need or health safety or welfare is at risk or competition is in adequate. 

PAULA: Go ahead. I was going to give you a break for a second. Make sure you take affirmative steps to work with businesses. It is interesting the regulations do not include disability owned. You can certainly take that into consideration requirements are affirmative steps to minority veterans and women owned businesses and that could include dividing up the work between more than 1 contractor so this can happen. Or if you have a contractor and subcontractors requiring your contractor to seek out subcontractors that meet these requirements. So you are doing affirmative action in some way to assist minorities. 

JOHN: The veteran owned businesses was added fairly recently so if you are updating your policy is not likely veteran owned businesses have been in there, so be sure to check for that. There should also be a preference for material source in the US goods manufactured in the US. If we can move on to the next slide. Uniform Administrative Requirements which is the HHS regulation and uniform guidance itself, both require standards for your procurement policy. You need to follow your own documented procedures which are in sync with state and local laws and regulations and they have to conform to the federal laws as well that is what we have been talking about here. You have to have written standards of conduct for conflict of interest governing the actions of employees engaged in the selection award administration of these contracts. Periodically review and update your procurement policies to align them with the latest federal guidelines. Paula, do you have thoughts on how often policies in general should be updated? 

PAULA: I like to see some kind of a committee or read through every year for your policies and procedures. It doesn't mean you will update them every somebody often the policy committee or board should look at them to make sure they still make sense. I have found a couple of typos in this presentation we found after it had been sent off to be finalized so we weren't able to fix them you will find the same thing your policies. Sometimes it will change somebody's title and realize their reference the policies. A finance committee might look at this document policy and a different committee might look personnel policies. If you don't have a large board, you may divide it up and say this year we are going to cover these policies and next year the others I would never go more than three years of any policy I prefer to see them manually because you catch stuff you don't realize you change in thing we aren't at that address anymore why do I have that in my policy? We no longer call that person the HR person, now we call them the personnel expert, whatever you are doing in life it is flexible and always changing. Sometimes you will run across something and say we stopped doing that long ago why have we got that in a policy. Remember what John said minute ago if you are reviewed you will be held to your own policies. If you have got some you don't do anymore you need to start doing it or take it out. I like to see an annual review split up between board committees if you don't have a large enough board, you can have staff do internal reviews and come back with suggestions for changes. Look at it not less than three years and preferably annually for at least reading through. I do the same thing with bylaws somebody ought to read bylaws every year they have things in them that are bound by somebody ought to read the things that set your requirements on a regular basis to make sure they are still operational. 

JOHN: Since these policies need to be board approved, I would think if you make minor tweaks because there have been changes in titles or something of that nature, you would not need to have board approval. By the way, board approval should be documented in the minutes because if it's not then the board didn't approve it. When your federal reviewer comes to look at it or your auditor. Is that consistent with your thinking, Paula, minor things, you can do updates but anything major should be in ‑‑ 

PAULA: Anything that changes your practice should receive board approval if you are fixing the other things that don’t require board approval. 

JOHN: On the next slide we have guidelines for what would be a conflict of interest. It says no employee, officer or agent may participate in selection, award or administration of a contract supported by a federal award if he or she has a real or apparent interest and here's a good definition a conflict of interest would arise when the employee, officer, agent, member of their immediate family his or her partner or organization who employees any of them or about to employ any of them has a financial interest or potential tangible personal benefit from a firm being considered for a contract. That's a pretty good definition. 

PAULA: What you do about a conflict of interest we will talk about but first you need to identify it, and this identifies it pretty clearly. If you have a question drop it in the chat if you are not clear but your procurement policy as to include this and we recommend a code of ethics for your board, often for your staff that includes similar language so everybody is on board to say we are not going to tolerate conflicts of interest or situation where someone takes advantage of their position in order to gain something. 

JOHN: The next slide. It says the officers, employees and agents of the nonfederal entity now we are calling ourselves recipient, may neither solicit or accept gratuities, favors or anything of monetary value from contractors or parties to subcontract. Although, there may be situations where a gift is minor sort of a token or item of nominal value, that would not lead to a disciplinary action because right after that we say standards of conduct must provide for disciplinary action to be applied for violations and that has to be in your policy. 

PAULA: You have all seen this. You have got the business that comes by and leaves you chocolate Christmas for you to share that's not a substantial benefit to somebody it's a small gratuitous kind of gift that expresses customer appreciation without giving somebody an undue benefit, those small things are allowed, whatever they are. 

JOHN: Next slide. Your written procedures must avoid acquisition of unnecessary or duplicative items and consideration should be given to consolidating or breaking out documents to obtain a more economical purchase. Where appropriate, and analysis of lease versus purchase alternatives and any other appropriate analysis to determine the most economical approach. Part of this is just a mindset. We talked about do we need this item to carry on this contract, but the next consideration might be do we need to own this item and do we need this specific item or some variation? That is sort of a mindset to be a responsible purchaser. It is more than a mindset. You really need to document this, you need to document you are going to do that. When you do your purchase, you need to document you did do it. 

PAULA: Think why would you do a lease purchase versus a purchase the first place and 1 of the main reasons has to do with maintenance of the item. Thank through those things is this a high maintenance item? Am I going to pay to fix it if I buy it, or can I listen if it's not operating, I send it back and they bring me a different one. Is that reasonable for this kind of a purchase? In the long run is the cost about the same per year or even less maybe to do a lease instead of a purchase? Look at that option and determine some things about that. Sometimes you will see lease purchases and that is a little different you are purchasing the item in that case. Look at the requirements and look at the benefits that make your salesperson earn it, have them explain in detail how this is better whichever one you are choosing and then document that and keep it in the records along with that item. 

JOHN: Paula, the next comment we talked about agency should be encouraged to enter into state and local intergovernmental agreements, does that happen as a practical matter? 

PAULA: It does sometimes it happens most with state associations of centers there are state associations some states have a lot of centers, 20 or more and they can do group purchasing and often they can do that through their state association. State Association sets up the contract with the office supply company or whoever is you all in common would want to make purchases from office supplies the most common. You can get a discount for that. There are some states that consider the nonprofit network to also be eligible to buy into their governmental agreements. That is something you can look at. If you are receiving city or county funds sometimes you can work through your city or county and kind of tag on to their agreement usually it benefits you both because they have a higher Volume so their discount is a little less and you have the option to get there discount. We do see a little of that. It doesn't happen maybe as often as it could when you are looking for pinching pennies you need to think about these different options. Insurance is another that is sometimes a shared cost so group insurance plans that has more than 1 nonprofit as part of the group would be the other 1 I sometimes see. 

JOHN:  I am a member of our Rotary club serving a life sentence as treasurer, but we buy lawnmowers, big writing lawnmowers and we have a beautiful camp a charitable trust has a camp fully accessible including a climbing wall and treehouse. We can buy these lawnmowers to a state contract and sell them two years later what we paid for them so it is basically like free maintenance piece of equipment. It's a wonderful collaboration. 

PAULA: That is a great example. 

JOHN: Next slide, please. Again, we’re talking about the bigger contracts year but these rules I'm going to apply in general. No action should be taken to limit competition, any biases that come out of a conflict of interest, no unreasonable requirements on firms that would eliminate some firms in favor of others. Note requirements for experience that really isn't needed or excessive bonding, there might be circumstances where a brand name product would be required, generally, you would want to avoid specifying a brand name and any other action that would limit who could bid in a procurement process. 

PAULA: Absolutely. In small towns, sometimes rural areas, you have fewer possible suppliers look at costs because you often have competition be on your local community. 

JOHN: Next slide. Recommendations and selection of the contract the bidder should be based on skill and experience of the personnel the experience providing services or products to your organization their commitment to the nonprofit sector, information you may receive from other centers or other references there commitment to deadlines which can be critically important in some cases. As we said to the extent possible preference for products and services that can serve natural resources and protect the environment. 

PAULA: Let's say you're looking for something like a remodel of a current building. You are not going to want to have that in their hands and unavailable to you for a long period of time you are going to want to talk those time references and deadlines as part of your procurement decision because if you have to rent temporary space and that extends 3 months longer than planned you extended the cost of this by about three months' rent so were they really the low bid? They can't do what you need them to do you need to be able to sort that out. 

JOHN: Next slide. Contractors who develop our draft specifications or requirements for a project cannot bid on them. You can see the strong potential for a conflict of interest if they did. The solicitation should include a clear and accurate description of the technical requirements of the material, product or services to be provided. Documentation for the procurement and selection of the contract should be able to stand on its own. In other words, somebody should be able to review the documentation and see the process you followed by reaching out for bids and selecting the bidder. I was going to say documentation should be kept for at least three years and we say generally at least three years after you filed your annual nonprofit organization return and in some cases as long as seven years. 

PAULA: ACL likes to see that longer, that documentation being kept longer. There are things you're not required to keep longer than that but it is just smart personnel matters financially that kind of thing. 

JOHN: On the next slide it reminds us for some construction contract the prevailing wage requirements of the Davis‑ Bacon act may be required. 

PAULA: We say you might want to exceed the ADA you want to look at the personal needs of your consumers and staff and make sure as an example we decided to put in a short sink as well as a tall single people could will under in addition to the other sink at the normal height, because we felt like that would give much more variety and we had people who were shorter in stature. It was that or put a foot stool in and that didn't seem like a good idea we made one of the sinks lower. [Dog barking]. The neighbor is making noise in my companion ‑‑ I'm going to mute again. 

JOHN: If we can go on to the next slide there are resources here that you should hang onto. These can be helpful. The final thoughts on the next slide, review the sample procurement policy that is going through updates now not sure how quickly that will be out but that will be updated shortly. Once again, your policy isn't a policy until your board adopted. Your policy isn't an operating policy until the staff who are responsible for your procurement have been trained in it and that training should be an ongoing training not only as a reminder but to make sure if you have staff turnover, they are well aware and continuing to comply with the policy. 

PAULA: One of the things and this is true of any policy, one of the things you need to remember if you are reviewed you will be held to your own policies it is true of any policy. If they don't know and don't follow that and can't communicate this is how I do that whatever it is in a policy it really isn't being followed. That applies to procurement, which is kind of a complicated long policy but also applies to all of your policies and procedures and you are required to have quite a few of them. Certainly, keep that in mind as you go along. I think I want to go back, wait. I want to go back one. This set of resources these links can be clicked on when you are in the page with the training is posted. Keep that in mind and we do have some other policies we follow. We have the first of these three in this cohort and we will have another training next week to kind of close out this particular cohort. There is the general procurement standards found in the Federal Regulations and there is also guidance on the ACL website. These are pretty important resources for you to have available to yourself. Make sure you are aware of. Maybe bookmark some of this and have it available as you deal with finance I think you find these are resources you will refer to. That is what I find, I refer to them and go back and say what exactly was that regulation again? I want to make sure to get it right and I think you will find it helpful. You can always reach out to me at the T&TA center I reach out to John as needed in addition to that for that individual help as well. Be sure that you remember that. Now, you can go to that evaluation slide, Tyler.

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