Corrective Action Plans

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Program: AL 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: NEMA has implemented a process, effective immediately, to review the information submitted by subrecipient organizations regarding their 2 CFR Single Audi...
Program: AL 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: NEMA has implemented a process, effective immediately, to review the information submitted by subrecipient organizations regarding their 2 CFR Single Audit Certification. Responses will be cross-referenced with our own records of Federal funds passed through NEMA to the subrecipient. Any subrecipient responding that it was not required to conduct a single audit will prompt NEMA to validate against payment data. Any subrecipient’s noncompliance will be followed up by NEMA staff. Contact: Erv Portis Anticipated Completion Date: February 11, 2025
Program: AL 93.778 – Medical Assistance Program – Special Tests and Provisions Corrective Action Plan: Program Integrity staff will continue to attempt to update cases at least every 30 days when case totals are at or below 25 and every 45 days when higher than 25. Trainings and regular conversa...
Program: AL 93.778 – Medical Assistance Program – Special Tests and Provisions Corrective Action Plan: Program Integrity staff will continue to attempt to update cases at least every 30 days when case totals are at or below 25 and every 45 days when higher than 25. Trainings and regular conversations emphasize the need for descriptive narrative entries. As a result, the narrative entries will be more descriptive of the status of the case. For the exception reporting, the team continues to work on developing alternatives to using the reports in the Fraud Abuse Detection System. Concerning the misreported check, Program Integrity staff will give the Financial Team accurate information about collected refunds. The Department will ensure reports are accurate and make any necessary adjustments. Contact: Anne Harvey, Heather Arnold Anticipated Completion Date: 6/30/2025
View Audit 348113 Questioned Costs: $1
Finding 530047 (2024-053)
Significant Deficiency 2024
Program: AL 93.778 – Medical Assistance Program; AL 93.778 – COVID-19 Medical Assistance Program – Allowability Corrective Action Plan: The Department has been actively working with program, technology, and the EVV vendor to implement system controls to address the deficiencies identified in this...
Program: AL 93.778 – Medical Assistance Program; AL 93.778 – COVID-19 Medical Assistance Program – Allowability Corrective Action Plan: The Department has been actively working with program, technology, and the EVV vendor to implement system controls to address the deficiencies identified in this and prior year’s findings. The Department has two system change releases scheduled, the first in February 2025 and the second in late June 2025 to implement additional system improvements. Contact: Jeremy Brunssen Anticipated Completion Date: 7/1/2025
View Audit 348113 Questioned Costs: $1
Program: Various, including AL 93.778 – Medical Assistance Program (Medicaid) – Allowable Costs/Cost Principles Corrective Action Plan: OCIO - To resolve the identified overcharge and reduce the Internal Service Fund Balance, OCIO conducted an 8 month no-bill period from December 2023 through Jun...
Program: Various, including AL 93.778 – Medical Assistance Program (Medicaid) – Allowable Costs/Cost Principles Corrective Action Plan: OCIO - To resolve the identified overcharge and reduce the Internal Service Fund Balance, OCIO conducted an 8 month no-bill period from December 2023 through June 2024. During this time OCIO customer agencies would have seen a significant reduction in charges and OCIO’s fund balance significantly decreased. In addition, a full and thorough review of all OCIO rates was conducted. This review resulted in the decrease in any mainframe related rates by 30% from the previous years (State FY2021 and FY2022). DAS Materiel – The Print Shop will have the new rates developed and effective July 1, 2025, the beginning of the new biennium. Contact: OCIO - Noah Finlan; Materiel, Print Shop, Internal Service – Ann Martinez. Anticipated Completion Date: OCIO - Corrective action has already been taken and the fund balance is currently below the allowable threshold permitted. As of September 30, 2024, the fund balance was approximately $10 million dollars. Rates have been adjusted to be more in line with actual expenditures for FY2025. Print Shop – July 1, 2025.
View Audit 348113 Questioned Costs: $1
Program: AL 93.778 – Medical Assistance Program; AL 93.767 – Children’s Health Insurance Program (CHIP) – Special Tests and Provisions Corrective Action Plan: System changes were implemented with the Provider Screening Vendor on July 1, 2024, which require disclosure requirements for managing emp...
Program: AL 93.778 – Medical Assistance Program; AL 93.767 – Children’s Health Insurance Program (CHIP) – Special Tests and Provisions Corrective Action Plan: System changes were implemented with the Provider Screening Vendor on July 1, 2024, which require disclosure requirements for managing employees. Contact: Melinda Abbott Anticipated Completion Date: 12/6/2024
View Audit 348113 Questioned Costs: $1
Finding 530029 (2024-049)
Significant Deficiency 2024
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The agency will update the grant reconciliation process to include steps to review journal entries on the general ledger prior to moving costs to grant to ensure journal entries are proper. The cost in question wi...
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The agency will update the grant reconciliation process to include steps to review journal entries on the general ledger prior to moving costs to grant to ensure journal entries are proper. The cost in question will also be removed from the grant. Contact: Ann Murphy Anticipated Completion Date: 02/28/2025
View Audit 348113 Questioned Costs: $1
Program: AL 93.658 – Foster Care Title IV-E – Allowable Costs/Cost Principles Corrective Action Plan: Program will review training manual and update as necessary. The Agency will also communicate the importance of utilizing the master case file to correctly determine survey selections. Contact...
Program: AL 93.658 – Foster Care Title IV-E – Allowable Costs/Cost Principles Corrective Action Plan: Program will review training manual and update as necessary. The Agency will also communicate the importance of utilizing the master case file to correctly determine survey selections. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025
View Audit 348113 Questioned Costs: $1
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Subrecipient Monitoring Corrective Action Plan: The Refugee Resettlement Program is implementing a personnel report requirement for all subrecipients. According to federal guidel...
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Subrecipient Monitoring Corrective Action Plan: The Refugee Resettlement Program is implementing a personnel report requirement for all subrecipients. According to federal guidelines, personnel reports will show the time allocated to grants and the percentage related to all grants and include the corresponding timesheets or time records. Contact: Sara Bockelman Anticipated Completion Date: 10/1/2025
View Audit 348113 Questioned Costs: $1
Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Subrecipient Monitoring Corrective Action Plan: The agency will develop a monitoring plan to utilize for subrecipient monitoring. Contact: Matt Thomsen Anticipated Completion Date: 7/31/2025
Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Subrecipient Monitoring Corrective Action Plan: The agency will develop a monitoring plan to utilize for subrecipient monitoring. Contact: Matt Thomsen Anticipated Completion Date: 7/31/2025
View Audit 348113 Questioned Costs: $1
Program: AL 84.048 – Career and Technical Education – Basic Grants to States – Allowability Corrective Action Plan: The Nebraska Department of Education’s Office of Career, Technical, and Adult Education will carry out the following actions to improve procedures to ensure that all payments are su...
Program: AL 84.048 – Career and Technical Education – Basic Grants to States – Allowability Corrective Action Plan: The Nebraska Department of Education’s Office of Career, Technical, and Adult Education will carry out the following actions to improve procedures to ensure that all payments are supported by adequate documentation: Provide ongoing technical assistance to subrecipients and NDE staff to ensure they are familiar with and fully informed on the documentation necessary to process reimbursement for all types of expenditures. Ensure all subrecipients have a stipend policy in writing. Conduct regular desk audits to ensure subrecipients are adhering to all applicable state and federal laws and regulations. Contact: Katie Graham, Sydney Kobza, Teri Sloup Anticipated Completion Date: June 2025
View Audit 348113 Questioned Costs: $1
Program: AL 93.778 - Medical Assistance Program; AL 93.959 - Block Grants for Prevention and Treatment of Substance Abuse; AL 93.767 - Children’s Health Insurance Program; AL 93.575 – Child Care and Development Block Grant; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutri...
Program: AL 93.778 - Medical Assistance Program; AL 93.959 - Block Grants for Prevention and Treatment of Substance Abuse; AL 93.767 - Children’s Health Insurance Program; AL 93.575 – Child Care and Development Block Grant; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: The entire payroll process is being reviewed and changes will be made. Contact: Heather Arnold Anticipated Completion Date: 12/30/2025
View Audit 348113 Questioned Costs: $1
Finding 529992 (2024-038)
Significant Deficiency 2024
Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – A...
Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Social Services Block Grant; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: Time and Effort: Agency has submitted retroactive PACAP amendment (complete). For the IST Fiscal Projects Admin cost center, a time study will no longer be utilized, and the hours will be treated as General IST Administration without direct grant allocations. RMTS Allocations: Agency has clarified with staff what the “Non-DHHS Activities” selection pertains to (complete). Labor Hours Statistics: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Recipient Counts: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025
View Audit 348113 Questioned Costs: $1
Finding 529991 (2024-037)
Significant Deficiency 2024
Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Soci...
Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Social Services Block Grant; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025
View Audit 348113 Questioned Costs: $1
Management’s Response and Corrective Action Plan: Alpine Achievers Initiative acknowledges the finding and recommendation. Charging of unallowable costs and activities occurred due to a staff error and the final review of all expenditures prior to submitting report/reimbursement requests did not ide...
Management’s Response and Corrective Action Plan: Alpine Achievers Initiative acknowledges the finding and recommendation. Charging of unallowable costs and activities occurred due to a staff error and the final review of all expenditures prior to submitting report/reimbursement requests did not identify and correct this issue as it was included as part of payroll. Management will continue to strengthen financial oversight to prevent similar errors in the future. Since the audit finding, management has engaged a CPA firm with expertise in federal grants to provide bookkeeping and CPA services. This firm is well-versed in federal grant regulations and would have identified the AmeriCorps Education Award charge as unallowable before submission. Additionally, management has taken proactive measures to cross-train staff on this error, ensuring that multiple team members are aware of the restrictions on charging such costs to the grant. This training ensures that, should a similar unusual circumstance arise in the future, staff will recognize the issue and flag it before submission. Moving forward, Alpine Achievers Initiative will implement enhanced review processes to verify that all expenditures align with the Uniform Guidance and grant guidelines before reimbursement requests are submitted. Contact and Completion Date: Megan Strauss (megan@alpineachievers.org) is the primary contact, and the Executive Director at Alpine Achievers Initiative The correction action is expected to be resolved before the end of the next fiscal year-end of July 31, 2025.
View Audit 348100 Questioned Costs: $1
Temporary Assistance for Needy Families – Assistance Listing No. 93.558 and Foster Care Title IV-E - Assistance Listing No. 93.658 Recommendation: Management uses full time equivalent reports to determine what percentage of time spent should be allocated to the federal grant. During testing of payro...
Temporary Assistance for Needy Families – Assistance Listing No. 93.558 and Foster Care Title IV-E - Assistance Listing No. 93.658 Recommendation: Management uses full time equivalent reports to determine what percentage of time spent should be allocated to the federal grant. During testing of payroll expenses, we noted that one employee was not listed on the full time equivalent report for one month. We recommend that management implement a review process that compares the employees on the full time equivalent report to the list of active employees to ensure all employees are included in the full time equivalent report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The CFO will review the full time equivalent reports to ensure all employees are included in the full time equivalent reports. Additionally, general ledgers will be reviewed for all Federal spending against the full time equivalent reports to ensure consistency. Name(s) of the contact person(s) responsible for corrective action: Laura Stein, Chief Financial Officer Planned completion date for corrective action plan: March 31, 2025
Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A2200014, S010A230014 Pass-Through ...
Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers: S010A210014, S010A2200014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Condition: The School Corporation had not established an effective internal control system related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. The School Corporation failed to comply with the allowable costs/cost principle requirements that employees who work 100 percent of their time on a federal award maintain semiannual certifications as required by the pass-through agency, and that employees who work on a federal award and a non-federal award have Program Activity Reports or equivalent documentation to support the distribution of their salaries or wages. Context: Semiannual certifications are required by the pass-through agency. The required supporting documentation (Personnel Activity Reports, Semi-Annual Certifications, or equivalent documentation) for 4 of 40 payroll transactions selected for testing was not maintained properly. Payroll expenditures account for approximately $1.264 million of total program expenditures of $1.318 million. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan. Responsible party and timeline for completion: Kendra Sandquist, Director of Finance has established monthly grant meetings beginning July 2023 with Morgan Stout, Director of Curriculum, Instruction, and Assessment. Meetings include discussions on grant applications and timelines, reasonable, allowable, and allocable grant expenditures, benchmarking/grant progress, and requesting grant reimbursements. Review of grant-funded positions and their time and effort has been incorporated into these meetings to ensure the required supporting documentation is collected and maintained. This Corrective Action was completed on February 5, 2025.
COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform A...
COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Carmen López, Interim Finance Director Phone: (787) 869 – 2200 Original Finding Number: 2024-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: The authorized personnel understand the reporting requirements. We are in the process of training additional personnel to have more resources to comply with all reporting requirements. The Finance Department is working with external consultants to address this situation and be able to comply with all reports as required. Implementation Date: June 30, 2025 Responsible Person: Carmen I. López – Interim Finance Director
Condition: Time and effort certifications were not maintained for grant employees. Corrective Action Planned: We will utilize the template provided by the auditors to ensure time and effort certifications are maintained going forward. Anticipated Completion Date: July 1, 2025 Contact: Martin ...
Condition: Time and effort certifications were not maintained for grant employees. Corrective Action Planned: We will utilize the template provided by the auditors to ensure time and effort certifications are maintained going forward. Anticipated Completion Date: July 1, 2025 Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools
View Audit 347918 Questioned Costs: $1
Responsible personnel will ensure required prior approval for all projects involving federal funds is obtained prior to moving forward with all federally funded projects.
Responsible personnel will ensure required prior approval for all projects involving federal funds is obtained prior to moving forward with all federally funded projects.
View Audit 347868 Questioned Costs: $1
Condition: There was no evidence of a system of internal control over the cash management requirements, including a written policy related to reimbursement of funds on a per-refugee basis. In addition, it was noted that reimbursement was requested prior to incurring expenses on a per-refugee basis....
Condition: There was no evidence of a system of internal control over the cash management requirements, including a written policy related to reimbursement of funds on a per-refugee basis. In addition, it was noted that reimbursement was requested prior to incurring expenses on a per-refugee basis. There were also refugee costs coded incorrectly within the general ledger. Planned Corrective Action: Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that individual refugee costs were coded to the correct general ledger account. Contact person responsible for corrective action: Linda P. Foster, CEO Anticipated Completion Date: Refugee ledger reconciliation process completed 2/1/2025 Policy approval and implementation to be completed by 5/1/2025
Finding 529772 (2024-001)
Significant Deficiency 2024
Federal Agency Name: Department of Homeland Security Federal Financial Assistance Listing #97.036 Program Name: COVID-19 Disaster Grants - Public Assistance Finding Summary: Audit testing identified eleven instances where contract labor costs were over claimed under the program due to a calculation...
Federal Agency Name: Department of Homeland Security Federal Financial Assistance Listing #97.036 Program Name: COVID-19 Disaster Grants - Public Assistance Finding Summary: Audit testing identified eleven instances where contract labor costs were over claimed under the program due to a calculation error. Monument Health's methodology for identifying contract labor attributable to COVID to be based upon identifying total contact labor and multiplying by the percentage of COVID patient days as a percentage of total patient days. The methodology also identified certain cost centers were to be excluded from the calculation, including behavioral health and med/surg nursing. Based upon review of management's allocation percentage, it was noted the behavioral health and med/surg nursing COVID patient days were included within the total COVID patient days; therefore, a higher percentage of COVID patient days to total patient days was calculated. The calculation percentage was then utilized to calculate contract labor attributable to COVID for contract labor costs identified from July 2, 2022 through May 11, 2023. Responsible Individuals: Austin Willuweit, Chief Financial Officer Jen Schmaltz, Vice President of Finance Corrective Action Plan: Monument Health will review future calculations for consistency and accuracy. Anticipated Completion Date: June 30, 2025
View Audit 347766 Questioned Costs: $1
The County did not submit semi-annual status reports by the due dates and the reports were late by a few days. Management has discussed with staff and a plan will be developed to ensure reports and signatures will be prepared and submitted by the due dates.
The County did not submit semi-annual status reports by the due dates and the reports were late by a few days. Management has discussed with staff and a plan will be developed to ensure reports and signatures will be prepared and submitted by the due dates.
CORRECTIVE ACTION PLAN March 19, 2025 U.S. Department of Health an-d Human Services Employee & Family Resources, Inc. respectfully submits the following corrective action plan for the year ended 06/30/24. Name and address of independent public accounting firm: BerganKDV, Ltd.; 220 Park Ave South; St...
CORRECTIVE ACTION PLAN March 19, 2025 U.S. Department of Health an-d Human Services Employee & Family Resources, Inc. respectfully submits the following corrective action plan for the year ended 06/30/24. Name and address of independent public accounting firm: BerganKDV, Ltd.; 220 Park Ave South; St. Cloud, MN 56301 Audit period: July 1, 2023 - June 30, 2024 he finding from the scheduleoflindmgs and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Federal Award Finding Significant Deficiency Finding 2024-001: Proper Support for Payroll Cost Allocations Recommendation: We recommend that the Organization utilize the time and effort reporting system that ensures payroll costs are charged to federal awards based on actual hours worked and to train employees to properly code their hours. If actual hours are not used, management should review and adjust salary allocations periodically to align with documented time records. Action Taken: We concur with the recommendation. Information from the time and effort reporting system will support the payroll costs for the year July 1, 2024 - June 30, 2025. Beginning July 1, 2025, payroll costs charged to federal awards will be based on actual hours worked during the calendar month. Additional training has been conducted with staff and supervisors. Questions regarding this plan can be addressed to me at 515.471.2360. Sincerely, Tammy Hoyman CEO
Controls will be implemented for future reporting and the School will have the opportunity to correct the reporting errors in the subsequent periods.
Controls will be implemented for future reporting and the School will have the opportunity to correct the reporting errors in the subsequent periods.
On or before June 30, 2025, PEBC will implement controls that properly support the distribution of student educator teststipends in accordance with the Uniform Guidance. Controls shall include: • Standardized Documentation: Finance & Accounting Department will work with the Residency Department to d...
On or before June 30, 2025, PEBC will implement controls that properly support the distribution of student educator teststipends in accordance with the Uniform Guidance. Controls shall include: • Standardized Documentation: Finance & Accounting Department will work with the Residency Department to develop and maintain a clear inventory of required documents for each stipend award. • Resident File Management: Residency Department will establish a consistent and complete portfolio of documents for each student educator, including applications, agreements, award letters, diligence documents, and relevant correspondence. • Manager Review & Approval: Residency managers will review and attest to the completeness of each Resident File with documented approvals. • Disbursement Authorization: Finance & Accounting Department will work with the Residency Department to implement a formalized process to formalize and document requests to the Finance and Accounting Department for fund disbursement, including documentation of Residency Department manager approval. • Monthly Reconciliation: Finance & Accounting Department and Residency Department will conduct monthly reconciliations of all stipend disbursements to ensure accuracy and completeness. • Independent Oversight: Require approval of monthly reconciliations by an authorized manager who is not responsible for either approving, processing, or reconciling disbursements, or any combination thereof.
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