Corrective Action Plans

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Corrective Action: deferred Capital Fund Program (CFP) revenue balance of $15,076 resulted from IHA inadvertently drawing funds from the incorrect CFP grant to pay an eligible expense. When the error was discovered, IHA drew the funds from the correct CFP grant and applied an eligible expense to the...
Corrective Action: deferred Capital Fund Program (CFP) revenue balance of $15,076 resulted from IHA inadvertently drawing funds from the incorrect CFP grant to pay an eligible expense. When the error was discovered, IHA drew the funds from the correct CFP grant and applied an eligible expense to the CFP grant that had previously been drawn down, net zeroing the error. To ensure CFP funds are drawn only to cover valid expenses and no more than three (3) days in advance of disbursement, as required by the HUD Capital Fund Guidebook (2016) and 2 CFR 200.305(b), IHA has implemented the following internal control procedures over CFP cash management: 1. Draw Timing. CFP funds will be drawn in eLOCCS only after an invoice has been received, approved, and scheduled for payment, or after payment has been issued. No draw will be requested more than three (3) days before the related disbursement, and the amount drawn will not exceed the approved invoice amount. 2. Grant Verification Before Each Draw. Each eLOCCS draw will be supported by a CFP Draw Request worksheet identifying the vendor, invoice number, amount, CFP grant number, and Budget Line Item (BLI). Before submission, the grant number and BLI will be verified against the approved Annual Statement/Performance and Evaluation Report (form HUD-50075.1) and the invoice to confirm the expense is charged to the correct grant year. 3. Segregation of Duties. The staff member who prepares the draw request will not be the same individual who approves the draw in eLOCCS. The CEO will review and approve each draw request and its supporting documentation before the draw is submitted. 4. Monthly Reconciliation. Each month, eLOCCS draws will be reconciled by grant number to CFP deferred CFP revenue account will be reviewed monthly, and any CFP funds that remain undisbursed more than three (3) days after a draw will be investigated and resolved. 5. Year-End Review. Before fiscal year-end close, the CEO and fee accountant will review the deferred CFP revenue account to confirm that all CFP funds drawn have been expended on eligible costs for the correct grant. 26 6. Correction of Future Draw Errors. Going forward, if a draw from the incorrect grant or a draw in excess of an eligible expense is discovered, IHA will not offset the error between grants. IHA will return the funds to HUD and then draw the correct amount from the correct grant, following HU Repayments greater than $2,000 will be remitted by wire transfer to the U.S. Treasury (FRB New York) for the U.S. Department of HUD (Ft. Worth, TX), with the complete grant number (PPN) entered in the third-party memorandum field. Department of HUD and mailed to US Bank, HUD-FAD Collections Ft. Worth, with the required cover letter. On the day of the wire transfer, IHA will email the HUD Office of the Chief Financial Officer (FWAC-AccountsReceivableDocuments@hud.gov), the PIH Field Office, and the PIH Office of Capital Improvements (PIHOCI@hud.gov), copying the designated OCFO contacts, using Backup documentation will include a copy of the wire transfer or check and a cover letter that identifies the reason for repayment, the source year of the federal appropriation, and the grant number (PPN). Once HUD has credited the returned funds, IHA will draw the eligible expense from the correct CFP grant, and the repayment and redraw documentation will be retained in the grant file. 7. Written Procedures and Training. cash management procedures, and all staff involved in CFP draws will be trained on them. Compliance will be monitored through the monthly reconciliation described above. Responsible Person: Tina Bartlett, CEO Implementation Date: Effective immediately If you have any further questions, please let me know. Contact Person: Tina Bartlett, CEO 4215 S. Hocker Dr., Bldg. 5 Independence, MO 64055 816-994-0204 4215
Management will draw down Capital Funds on the date the check is written to avoid drawing down too early.
Management will draw down Capital Funds on the date the check is written to avoid drawing down too early.
Finding 2026-002 Federal Grant Cash Management and Federal Financial Reporting Auditor reference: Schedule of Findings and Questioned Costs, page 38 Finding addressed: One federal grant cash draw was partially disbursed before related disbursements, resulting in $180,641 in questioned costs. The aud...
Finding 2026-002 Federal Grant Cash Management and Federal Financial Reporting Auditor reference: Schedule of Findings and Questioned Costs, page 38 Finding addressed: One federal grant cash draw was partially disbursed before related disbursements, resulting in $180,641 in questioned costs. The audit also identified an inaccurate Annual Federal Financial Report for the H8N award ending August 31, 2025. Planned corrective action 1. Reconstruct and reconcile the transactions. By November 2026, the CFO will complete a transaction-level reconciliation of the $180,641 identified by the auditor and review the relevant draws for the H80 and H8N awards cited. The review will tie draw requests to the general ledger, bank activity, payment dates, grant budgets, supporting invoices or payroll, periods of performance, and submitted Federal Financial Reports. 2. Resolve questioned costs and reporting discrepancies. By December 2026, management will determine, based on source documentation and applicable award requirements, the amount, if any, that requires correction; communicate the results to the appropriate HRSA grants management and payment-system contacts; and obtain direction on any required return of funds, adjustment, or corrected reporting. NHHC will implement required remedies and retain correspondence, approvals, and transaction evidence. The $180,641 will remain an open questioned-cost matter until resolved through the applicable agency process. 3. Establish pre-draw controls. By December 2026, the CFO will revise and implement written cash-management procedures that require a grant-specific drawdown worksheet for each request. The worksheet will document eligible expenditures already disbursed or actual immediate cash requirements, planned payment dates, budget and award-period eligibility, available cash, and the requested amount. A designated Finance preparer will document the calculation, and the CFO will approve each draw before submission; exceptions will be escalated to the CEO. 4. Strengthen Federal Financial Report controls. By January 2027, Finance will implement an FFR preparation and review checklist that requires reconciling award-specific financial records with reported expenditures, disbursements, unliquidated obligations (where applicable), and reporting-period dates. The CFO will independently review and approve each FFR before submission. In coordination with HRSA and the payment-system administrator, Finance will address the identified H8N reporting error through the permitted correction process. 5. Test and monitor compliance. By March 2027, the CFO will document a review of all grant draw requests submitted during the first three months of the revised process and of any FFRs submitted during that period. The review will verify completed pre-draw support, approvals, cash timing, and report reconciliation. Exceptions will be investigated, corrected, and tracked to closure, with a summary provided to the CEO. Responsible contacts: Jason Wallace, Chief Executive Officer; Monica Lerma, Chief Financial Officer Anticipated completion: March 2027 Evidence of correction: Transaction-level draw reconciliation and questioned-cost analysis; HRSA and payment-system correspondence; written cash-management and FFR procedures; approved draw worksheets; FFR support and approval checklists; bank and expenditure records; and post-implementation testing reports. Agency-dependent resolution: NHHC’s completion target excludes agency-controlled determinations of questioned costs and acceptance of corrected federal reporting.
The center corredcted the advance draw by expending the draws during the year ended Janaury 31, 2026 and did not complete an advance draw again in 2026. The center will review its cash management polcies to consider modification to account for certain circumnstances to allow for flexibility advance ...
The center corredcted the advance draw by expending the draws during the year ended Janaury 31, 2026 and did not complete an advance draw again in 2026. The center will review its cash management polcies to consider modification to account for certain circumnstances to allow for flexibility advance draws. The center will remit the excess interest earned to the Department of Health and Human Services.
H.S.C. No. 6 Housing Development Fund Co. Inc. agrees with the finding and the required deposit in the amount of $22,477 was made on August 24, 2026.
H.S.C. No. 6 Housing Development Fund Co. Inc. agrees with the finding and the required deposit in the amount of $22,477 was made on August 24, 2026.
Unearned Funds – Public Housing Capital Fund: HACM Management will process checks to be paid from Capital Fund on the same day that funds are drawn down in LOCCS but dated as of the date funds are expected to be deposited. Receipt of Capital Funds will be confirmed via online banking and then checks...
Unearned Funds – Public Housing Capital Fund: HACM Management will process checks to be paid from Capital Fund on the same day that funds are drawn down in LOCCS but dated as of the date funds are expected to be deposited. Receipt of Capital Funds will be confirmed via online banking and then checks sent out. Re: Federal Awards Findings: Unearned Funds - Sec􀆟on 8 Housing Choice Vouchers HACM Management will work closely with so􀅌ware vendor to ensure HAP amounts agree to the HAP contracts.
2026-001 Period of Performance Corrective action planned: The organization will implement an additional step to review personnel cost categories that may have the potential of including out-of-period costs (e.g., performance bonus payments, contractual lump sum payments) and verify that these expens...
2026-001 Period of Performance Corrective action planned: The organization will implement an additional step to review personnel cost categories that may have the potential of including out-of-period costs (e.g., performance bonus payments, contractual lump sum payments) and verify that these expenses are allocated to the correct award cycle. If out-of-period transactions are identified, the organization will ensure that these expenses are allocated to unrestricted general operating funds. Anticipated completion date: October 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer
Finding #2026-002 – Allowable Costs – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Agriculture, Assistance Listing #10.932, Regional Conservation Partnership Program, Contract period: 06/12/24 – 12/31/26 Contract number: Supplemental-2983-A-1608, Co...
Finding #2026-002 – Allowable Costs – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Agriculture, Assistance Listing #10.932, Regional Conservation Partnership Program, Contract period: 06/12/24 – 12/31/26 Contract number: Supplemental-2983-A-1608, Contract period: 10/31/23 – 07/31/27 Contract number: Supplemental-2757-A-1212, Contract period: 08/29/23 – 03/31/26 Contract number: 917442230013, Passed through Sul Ross State University: Contract period: 04/01/25 – 03/31/26 Contract number: N/A. Condition and context: Of the $1,838,681 expended during the year ended March 31, 2026, approximately $1,729,640 related solely to the purchase of a conservation easement. The remaining expenditures of $109,041 consisted of payroll and related charges. In a sample of three payroll transactions tested, we noted in each case that reimbursement requests were based on hourly rates that exceeded the actual rates of pay of the employees performing the work, resulting in an overstatement of payroll charged to the grantors of $14,668. Recommendation: Develop policies and procedures to ensure that all costs charged to federal awards are based on actual costs incurred in accordance with federal award requirements. Planned corrective action: Management will establish procedures to ensure personnel costs charged to federal awards are based on actual allowable employee compensation and supported by appropriate time records. Federal reimbursement requests will be reviewed by the Director of Operations and the Director of Finance prior to submission to ensure that billed costs comply with federal award requirements. Management will also review the questioned costs identified in the audit and coordinate with the applicable grantor regarding any required repayment or adjustment. Responsible officer: Dina McIlhenny, Director of Finance and Brenna Gaik, Director of Operations. Estimated completion date: October 31, 2026.
Management will implement measures to ensure the Organization will deposit “Surplus Cash” as defined by HUD, existing at the end of the fiscal year in a residual receipts account in the name of the Organization within 90 days subsequent to the end of the fiscal year.
Management will implement measures to ensure the Organization will deposit “Surplus Cash” as defined by HUD, existing at the end of the fiscal year in a residual receipts account in the name of the Organization within 90 days subsequent to the end of the fiscal year.
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will b...
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements. The Corporation has also applied for a rent increase in July 2026 that has yet to be approved as of this report’s issuance date.
Name: CABUN Rural Health Services, Inc. Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Auditor/Audit Firm: Forvis Mazars, LLP Audit Period: March 31, 2026 Federal Program: Health Center Cluster Anticipated Completion Date: October 2026 Response: The Organization concurs with the...
Name: CABUN Rural Health Services, Inc. Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Auditor/Audit Firm: Forvis Mazars, LLP Audit Period: March 31, 2026 Federal Program: Health Center Cluster Anticipated Completion Date: October 2026 Response: The Organization concurs with the finding, and management will implement formal written procedures and internal controls governing Federal cash drawdowns. The procedures will require Federal funds to be drawn only for actual, immediate cash needs and as close as administratively feasible to the related disbursements. Supporting documentation will be maintained to identify expenditures supporting the draw. The expenditures will be reviewed to verify that they are allowable, properly documented, incurred within the applicable Federal award period, and recorded in the appropriate accounting records. Federal draw requests will be reconciled to the underlying expenditures before submission. The individual responsible for preparing the draw will provide the supporting documentation and reconciliation for review and approval before the draw is submitted.
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its mont...
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements.
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will b...
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements.
After being informed of the finding, the Center instituted strategies to align drawdowns with near-term disbursement needs. However, these adjustments commenced during the subject fiscal year and will remain in place moving forward.
After being informed of the finding, the Center instituted strategies to align drawdowns with near-term disbursement needs. However, these adjustments commenced during the subject fiscal year and will remain in place moving forward.
Finding 1240661 (2026-001)
Material Weakness 2026
Finding: Adjusting Journal Entries and Account Reconciliation (2026-001) Two material journal entries related to grant funding were posted during the audit. Each caused additional expenditures to be added to the Schedule of Expenditures of Federal Awards. One of the entries was the recognition of in...
Finding: Adjusting Journal Entries and Account Reconciliation (2026-001) Two material journal entries related to grant funding were posted during the audit. Each caused additional expenditures to be added to the Schedule of Expenditures of Federal Awards. One of the entries was the recognition of indirect costs earned but not yet recorded related to the NOAA grant. Name of contact person responsible for corrective action: Landis Hudson, Executive Director. Anticipated completion date: September 30, 2026 Corrective Action Plan: Management now understands the importance of reconciling retainage, indirect costs allocations, and payables and will do so in a timely manner going forward.
Identifying Number: Item 2026-001 - Cash Management Finding During late April of 2026, the University requested and received approximately 508,000 of Federal Direct Loan funds in excess of the funds disbursed to eligible students. The excess funds were identified by the University during reconciliat...
Identifying Number: Item 2026-001 - Cash Management Finding During late April of 2026, the University requested and received approximately 508,000 of Federal Direct Loan funds in excess of the funds disbursed to eligible students. The excess funds were identified by the University during reconciliation procedures in May and were returned to the DOE in June of 2026, which was beyond the seven-day tolerance period. Management's Response The University agrees with the above referenced findings and is committed to maintaining compliance with the cash management requirements. Corrective Action Plan Management agrees with the recommendation that the University should improve the process utilized to generate the Financial Aid Feed Report (Feed Report). The corrective action will include two additional controls, one in the Financial Aid Office focused on generating accurate reports, and one in the Finance Department focused on ensuring the information contained in the Feed Report is accurate prior to submitting the reimbursement request to the U.S. Department of Education. Both of these additional controls are considered "prevent" controls as both are designed to prevent errors prior to seeking cash/reimbursement from the U.S. Department of Education. The added "prevent" controls are summarized as follows: 1. Financial Aid Department - To help prevent inaccurate information from being generated on the Feed Report, the Financial Aid Office has partnered with the University's Information Technology Department to automate the creation and distribution of the following reports to designated Financial Aid and Finance personnel on a regular basis. This automation will improve cash flow by providing Feed Reports in a more timely manner and will reduce reliance on manual processes previously utilized to generate and distribute the below referenced reports. · Weekly financial aid feed reports identifying Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), and Direct Loan disbursements posted to student accounts. · Monthly "year-to-date" feed reports for these same federal aid programs. The above automations are scheduled to begin following the University's upcoming Banner Cloud system go-live date on October 15, 2026. Prior to implementation of these automated processes, Financial Aid and Finance personnel are performing additional review and reconciliation procedures prior to the submission of the Feed Reports to the U.S. Department of Education to double check and confirm the accuracy of the information included in the Feed Reports. 2. Finance Department - The Finance Department will reconcile the information included on the Feed Reports with the University's general ledger thereby verifying the information received on the feed reports from Financial Aid matches the amount that has been posted to the general ledger prior to requesting the reimbursement from the U.S. Department of Education. Neal Stenzel, Chief Financial Officer, is responsible for the corrective action plan and the anticipated completion date is October 2026.
FINDING 2026-002 Name of Responsible Individual: Alex Putzer, AVP for Business & Finance Corrective Action: The University has implemented enhanced controls over Federal Pell Grant cash draws to ensure compliance with federal cash management requirements. The University will maintain an approximate ...
FINDING 2026-002 Name of Responsible Individual: Alex Putzer, AVP for Business & Finance Corrective Action: The University has implemented enhanced controls over Federal Pell Grant cash draws to ensure compliance with federal cash management requirements. The University will maintain an approximate $50,000 cushion between cumulative eligible financial aid disbursements and cumulative funds drawn through the G5 portal. Prior to each draw, cumulative financial aid awarded and recorded in the University’s general ledger will be reconciled to cumulative G5 draws to ensure funds requested do not exceed eligible disbursements. Additionally, the AVP for Business and Finance will review and approve each draw prior to submission to provide an additional level of oversight and ensure continued compliance with applicable federal cash management requirements. Anticipated Completion Date: September 30, 2026
Recommendation: The Organization should establish procedures to ensure surplus cash is calculated and deposited into the Residual Receipts account within the timeframe required by HUD. The Organization should also maintain documentation supporting the calculation and timely deposit of surplus cash. ...
Recommendation: The Organization should establish procedures to ensure surplus cash is calculated and deposited into the Residual Receipts account within the timeframe required by HUD. The Organization should also maintain documentation supporting the calculation and timely deposit of surplus cash. Views of Responsible Official: We will establish necessary procedures and ensure going forward all surplus cash are timely deposited.
1. Immediate Termination: Upon discovery of this error during the audit, EVMC immediately terminated the massage wellness benefit. 2. Reimbursement of Questioned Costs: EVMC will reimburse the Health Center Program (93.224) the full questioned amount of $4,356 using non-federal funds, as necessary.
1. Immediate Termination: Upon discovery of this error during the audit, EVMC immediately terminated the massage wellness benefit. 2. Reimbursement of Questioned Costs: EVMC will reimburse the Health Center Program (93.224) the full questioned amount of $4,356 using non-federal funds, as necessary.
Finding 1239975 (2026-001)
Material Weakness 2026
Audit Finding Reference: 2026-001 (Federal) Eligibility - Child and Adult Care Food Program, Assistance Listing 10.558 Planned Corrective Action: • Initial determination and first-level review. Participant eligibility is determined by the Site Director in accordance with the applicable CACFP Income ...
Audit Finding Reference: 2026-001 (Federal) Eligibility - Child and Adult Care Food Program, Assistance Listing 10.558 Planned Corrective Action: • Initial determination and first-level review. Participant eligibility is determined by the Site Director in accordance with the applicable CACFP Income Eligibility Guidelines. Income Eligibility Application forms are reviewed for completeness and accuracy by the Site Director. • Independent secondary review. Beginning September 2026, before any determination is transferred to the Master List used for claim reimbursement, TEAM's Early Childhood Quality Assurance Manager will independently review each determination by recalculating reported household income and household size and comparing the result to the current program-year Income Eligibility Guidelines. This applies to 100% of initial determinations and to every re-determination or mid-year change in reported household income or household size. • Guideline currency. The Quality Assurance Manager will obtain the Income Eligibility Guidelines issued for each program year upon publication, confirm that the table in use is the current-year table. • Documentation. The reviewer initials and dates each Income Eligibility Application. The eligibility category recorded on the Master List is traced to the reviewed form. Reviewed forms are retained for audit. • Correction of the identified errors. The two participants identified in the finding were reclassified as of April 2026. The claims will be amended post CACFP review in September 2026. Name of Contact Person: Jamie Peterson, Lead Director of Early Childhood Jpeterson@teaminc.org Designated backup: Jamie Cullen, Early Childhood Quality Assurance Manager jcullen@teaminc.org 203.757.8888 x3241 Completion date: September 15, 2026
Action Taken: Brescia University will establish a review system to verify that direct loan reconciliations are being completed monthly. This system will include: (1) monthly scheduled file requests between Financial Aid, Registrar (who pulls the data files from COD), and the Business Office. The fil...
Action Taken: Brescia University will establish a review system to verify that direct loan reconciliations are being completed monthly. This system will include: (1) monthly scheduled file requests between Financial Aid, Registrar (who pulls the data files from COD), and the Business Office. The file requests will be scheduled for the earliest date of the month possible based on the college calendar and completed within 10 business days. (2) Each monthly reconciliation will be double checked by a senior financial aid counselor upon completion and will be signed off on as a log/confirmation of completion of the reconciliation. (3) The logs/confirmations will be mainted by the Director of Financial Aid.
Finding 2026-003: Grant Account Reconciliation Procedures Type of Finding: Control U.S. Department of Housing and Urban Development Direct program Assistance Listing Number: 14.251 Award Numbers: B-24-CP-MI-1149 Award Year End: August 31, 2032 Recommendation: The Township should establish procedures...
Finding 2026-003: Grant Account Reconciliation Procedures Type of Finding: Control U.S. Department of Housing and Urban Development Direct program Assistance Listing Number: 14.251 Award Numbers: B-24-CP-MI-1149 Award Year End: August 31, 2032 Recommendation: The Township should establish procedures to verify that expenditures are properly tracked by each individual grant to ensure that individual disbursements are not allocated to more than one grant. Action Taken: The Township has created and is utilizing a spreadsheet to track expenditures by each individual grants that will be updated as individual disbursements and receipts occur. Responsible Person and Completion Date: Township Treasurer, March 31, 2026. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Rebecca Griffin at 231-861-5853.
The Cooperative returned the reimbursed funds to the replacement reserve. The management agent will implement a process to ensure that future reimbursed funds are returned to the replacement reserve as required by the regulatory agreement.
The Cooperative returned the reimbursed funds to the replacement reserve. The management agent will implement a process to ensure that future reimbursed funds are returned to the replacement reserve as required by the regulatory agreement.
Comments on the Finding and Each Recommendation: During the year ended May 31, 2026, $11,836 was withdrawn from the reserve for replacements without HUD approval. Management should transfer $11,836 from the operating account to the reserve for replacements account. Action(s) taken or planned on the ...
Comments on the Finding and Each Recommendation: During the year ended May 31, 2026, $11,836 was withdrawn from the reserve for replacements without HUD approval. Management should transfer $11,836 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding Agree. Management concurs with the finding and recommendation. On August 11, 2026, management transferred $11,836 from the operating account to the reserve for replacements account.
Comments on the Finding and Recommendations Concur or do not concur with this finding – Concur Agree or disagree with auditor recommendation – Agree Corrective Action Taken or Planned Response to Findings Identified by Auditor Completion date or proposed completion date – September 30, 2026 Actions ...
Comments on the Finding and Recommendations Concur or do not concur with this finding – Concur Agree or disagree with auditor recommendation – Agree Corrective Action Taken or Planned Response to Findings Identified by Auditor Completion date or proposed completion date – September 30, 2026 Actions taken or Planned on the finding – Management will establish a separate Residual Receipts bank account and implement internal controls and procedures to ensure that future surplus cash deposits are made to the Residual Receipts account within the timeframe required by HUD.
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