Audit 335174

FY End
2024-03-31
Total Expended
$50.93M
Findings
16
Programs
7
Organization: Springfield Housing Authority (MA)
Year: 2024 Accepted: 2024-12-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
517211 2024-003 Significant Deficiency Yes L
517212 2024-002 Significant Deficiency Yes L
517213 2024-002 Significant Deficiency Yes L
517214 2024-003 Significant Deficiency Yes L
517215 2024-004 Significant Deficiency - L
517216 2024-002 Significant Deficiency Yes L
517217 2024-002 Significant Deficiency Yes L
517218 2024-002 Significant Deficiency Yes L
1093653 2024-003 Significant Deficiency Yes L
1093654 2024-002 Significant Deficiency Yes L
1093655 2024-002 Significant Deficiency Yes L
1093656 2024-003 Significant Deficiency Yes L
1093657 2024-004 Significant Deficiency - L
1093658 2024-002 Significant Deficiency Yes L
1093659 2024-002 Significant Deficiency Yes L
1093660 2024-002 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
14.850 Public Housing Operating Fund $12.95M Yes 1
14.872 Public Housing Capital Fund $6.23M Yes 3
14.195 Project-Based Rental Assistance (pbra) $735,922 - 1
14.879 Mainstream Vouchers $269,058 Yes 1
14.871 Section 8 Housing Choice Vouchers $101,646 Yes 1
14.870 Resident Opportunity and Supportive Services - Service Coordinators $89,169 - 0
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $40,515 - 0

Contacts

Name Title Type
REEUQA24ZX31 Austin Harris Auditee
4137854511 Andrew Fox, CPA Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The schedule of expenditures of federal awards is presented on the accrual basis of accounting. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). De Minimis Rate Used: N Rate Explanation: Indirect costs are included in the reported expenditures to the extent such costs are included in the federal financial reports used as the source for the data presented. The Authority does not use the 10% de minimis election.

Finding Details

Criteria - The Authority must prepare a SEFA for the period covered by the Authority’s financial statements which must include the total Federal awards expended by individual Assistance Listing number as determined in accordance with §200.502 Basis for determining Federal awards expended. Condition - The Authority did not include $735,922 related to the Project-Based Rental Assistance (Assistance Listing No. 14.195) grant in its SEFA for the year ended March 31, 2024. The Authority also had a variance of $689,366 in its Public Housing Capital Fund Program (Assistance Listing No. 14.872) between the SEFA and the amount reported for audit. Cause - The Authority’s year-end closing and financial reporting procedures were not sufficient to ensure accurate financial reporting. Effect - The total expenditures of federal awards were understated by $1,425,288. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-004 as reported in the prior year. Recommendation - We recommend verifying the total amount of expenditures on an individual grant basis per review of the general ledger account balances prior to submitting the unaudited Financial Data Schedule (FDS). Management’s Response - (3) Finding 2024-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize Marcum LLP to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all general ledger activity is accurate to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - The Authority must prepare a SEFA for the period covered by the Authority’s financial statements which must include the total Federal awards expended by individual Assistance Listing number as determined in accordance with §200.502 Basis for determining Federal awards expended. Condition - The Authority did not include $735,922 related to the Project-Based Rental Assistance (Assistance Listing No. 14.195) grant in its SEFA for the year ended March 31, 2024. The Authority also had a variance of $689,366 in its Public Housing Capital Fund Program (Assistance Listing No. 14.872) between the SEFA and the amount reported for audit. Cause - The Authority’s year-end closing and financial reporting procedures were not sufficient to ensure accurate financial reporting. Effect - The total expenditures of federal awards were understated by $1,425,288. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-004 as reported in the prior year. Recommendation - We recommend verifying the total amount of expenditures on an individual grant basis per review of the general ledger account balances prior to submitting the unaudited Financial Data Schedule (FDS). Management’s Response - (3) Finding 2024-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize Marcum LLP to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all general ledger activity is accurate to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), for modernization projects, the Authority shall submit the Actual Modernization Cost Certificate (AMCC) (Form HUD-53001) and the final Performance & Evaluation Report (P&E) (HUD-50075.1) within 90 days after the Expenditure End Date (EED). Condition - The Authority did not submit the AMCC or P&E reports within 90 days after the EED for both MA01E035501-19 grant (EED - April 8, 2023) and MA01P035501-18 grant (EED - May 28, 2024). Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is not a repeat finding. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will implement controls to ensure all Capital Fund Program grants are accurately reported and finalized with HUD within the required due dates. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - The Authority must prepare a SEFA for the period covered by the Authority’s financial statements which must include the total Federal awards expended by individual Assistance Listing number as determined in accordance with §200.502 Basis for determining Federal awards expended. Condition - The Authority did not include $735,922 related to the Project-Based Rental Assistance (Assistance Listing No. 14.195) grant in its SEFA for the year ended March 31, 2024. The Authority also had a variance of $689,366 in its Public Housing Capital Fund Program (Assistance Listing No. 14.872) between the SEFA and the amount reported for audit. Cause - The Authority’s year-end closing and financial reporting procedures were not sufficient to ensure accurate financial reporting. Effect - The total expenditures of federal awards were understated by $1,425,288. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-004 as reported in the prior year. Recommendation - We recommend verifying the total amount of expenditures on an individual grant basis per review of the general ledger account balances prior to submitting the unaudited Financial Data Schedule (FDS). Management’s Response - (3) Finding 2024-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize Marcum LLP to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all general ledger activity is accurate to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - The Authority must prepare a SEFA for the period covered by the Authority’s financial statements which must include the total Federal awards expended by individual Assistance Listing number as determined in accordance with §200.502 Basis for determining Federal awards expended. Condition - The Authority did not include $735,922 related to the Project-Based Rental Assistance (Assistance Listing No. 14.195) grant in its SEFA for the year ended March 31, 2024. The Authority also had a variance of $689,366 in its Public Housing Capital Fund Program (Assistance Listing No. 14.872) between the SEFA and the amount reported for audit. Cause - The Authority’s year-end closing and financial reporting procedures were not sufficient to ensure accurate financial reporting. Effect - The total expenditures of federal awards were understated by $1,425,288. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-004 as reported in the prior year. Recommendation - We recommend verifying the total amount of expenditures on an individual grant basis per review of the general ledger account balances prior to submitting the unaudited Financial Data Schedule (FDS). Management’s Response - (3) Finding 2024-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize Marcum LLP to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all general ledger activity is accurate to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to HUD guidelines and Uniform Guidance (2 CFR 200.344) related to the Authority’s Public Housing Capital Fund Program (CFP) (Assistance Listing No. 14.872), for modernization projects, the Authority shall submit the Actual Modernization Cost Certificate (AMCC) (Form HUD-53001) and the final Performance & Evaluation Report (P&E) (HUD-50075.1) within 90 days after the Expenditure End Date (EED). Condition - The Authority did not submit the AMCC or P&E reports within 90 days after the EED for both MA01E035501-19 grant (EED - April 8, 2023) and MA01P035501-18 grant (EED - May 28, 2024). Cause - The delay in submission was due to ineffective internal controls over the closeout process of individual CFP grant years. Effect - Late submission or non-submission of the required reports could result in delayed reviews by HUD, potential penalties, and could affect the Authority’s eligibility for future funding. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is not a repeat finding. Recommendation - We recommend that the Authority enhance its internal controls to ensure timely submission of required reports. This could include implementing deadline tracking systems, providing additional training for staff responsible for report preparation, and establishing internal review processes to ensure compliance with reporting deadlines. Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will implement controls to ensure all Capital Fund Program grants are accurately reported and finalized with HUD within the required due dates. (c) Planned implementation date of corrective action - Completed by March 31, 2025.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.
Criteria - According to 2 CFR §200.512, non-federal entities must submit their audit reports, including financial information, to the Federal Audit Clearinghouse (FAC) within nine months after the end of the audit period. HUD-specific guidelines also require timely submission of financial data via the Financial Data Schedule (FDS) in the Real Estate Assessment Center (REAC) as part of the compliance requirements for entities receiving federal assistance. Condition - The Authority did not submit its audited financial information for the fiscal year ended March 31, 2023, to the FAC or to HUD via the FDS by the required deadlines. Cause - The Authority’s ongoing transition to the Yardi software platform has impacted its capacity to generate comprehensive financial information and adhere to the expected audit timelines. Effect - The Authority is currently not meeting the reporting requirements mandated for federal awards. Statistical Sampling - The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs - None identified. Repeat Finding - This is a repeat of finding 2023-003 as reported in the prior year. Recommendation - The Authority should work closely with Yardi representatives to address specific challenges and expedite the resolution of any system integration issues. Management’s Response - (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.