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Finding 34645 (2022-001)
Significant Deficiency 2022
Due to transitions in personnel and systems, written support for the approval of a request for reimbursement was not available. A new Director of Grants Accounting was hired in August 2023 and has reviewed and been trained on the cash management policy. Effective October 2023, written supporting d...
Due to transitions in personnel and systems, written support for the approval of a request for reimbursement was not available. A new Director of Grants Accounting was hired in August 2023 and has reviewed and been trained on the cash management policy. Effective October 2023, written supporting documentation of the review and approval of requests for reimbursement will be obtained and maintained by Grant Accounting staff, in accordance with March of Dimes policy and federal cash management requirements.
The Board will require approval for such expenditures made in short succession and for the bid process to be followed as required by law when the ultimate result of the transaction is a purchase of goods or services of an amount exceeding $20,000.
The Board will require approval for such expenditures made in short succession and for the bid process to be followed as required by law when the ultimate result of the transaction is a purchase of goods or services of an amount exceeding $20,000.
View Audit 29881 Questioned Costs: $1
United States Department of Education Education Stabilization Fund ? CFDA #84.425D/84.425U/84.425W Corrective Action Plan ? Noncompliance with Reporting Requirements Finding: 2022-003 Condition: The District has inadequate controls over reviewing and approving quarterly ?historical expenditure repor...
United States Department of Education Education Stabilization Fund ? CFDA #84.425D/84.425U/84.425W Corrective Action Plan ? Noncompliance with Reporting Requirements Finding: 2022-003 Condition: The District has inadequate controls over reviewing and approving quarterly ?historical expenditure reports? filed with the Illinois State Board of Education. Plan: The superintendent will review and approve quarterly ?historical expenditure reports? and supporting documentation on a regular basis prior to electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Jessica Sisil, District Superintendent
Corrective Action Plan: Catholic Charities Program Manager, Joanne Varnes, conducted a training on December 15, 2022 with all staff involved in the CACFP that included income eligibility/enrollment categorization and meal count accuracy. Catholic Charities staff will review each income form/enrollme...
Corrective Action Plan: Catholic Charities Program Manager, Joanne Varnes, conducted a training on December 15, 2022 with all staff involved in the CACFP that included income eligibility/enrollment categorization and meal count accuracy. Catholic Charities staff will review each income form/enrollment and double check that children?s reimbursement rate is properly categorized based on their family?s income. Staff members will review each claim before it is entered for reimbursement to ensure the claim is accurate. Program Manager, Joanne Varnes, will oversee this process and conduct case record reviews quarterly for all providers under Catholic Charities Sponsorship. Contact Person Responsible for Corrective Action: Fritz Jones, Executive Director Anticipated Completion Date of Corrective Action: Immediately
Reporting views of responsible officials and planned corrective actions Management will open a new residual account for this HUD entity and will put controls in place to ensure that the calculated surplus cash balance is deposited into the account, if applicable, annually.
Reporting views of responsible officials and planned corrective actions Management will open a new residual account for this HUD entity and will put controls in place to ensure that the calculated surplus cash balance is deposited into the account, if applicable, annually.
Reporting views of responsible officials and planned corrective actions Management will ensure that security deposits are tracked so they can be recorded accordingly when there is a move in and/or move out. Moving forward management will put in place controls to ensure that the calculation is done a...
Reporting views of responsible officials and planned corrective actions Management will ensure that security deposits are tracked so they can be recorded accordingly when there is a move in and/or move out. Moving forward management will put in place controls to ensure that the calculation is done at the end of the fiscal year.
FINDING 2022-002 Contact Person Responsible for Corrective Action: Sherry Lockard Contact Phone Number: 812-283-1500 Views of Responsible Official: The Town concurs with the finding. Description of Corrective Action Plan: The Town has assigned the duties to request reimbursement (LPA Invoice Voucher...
FINDING 2022-002 Contact Person Responsible for Corrective Action: Sherry Lockard Contact Phone Number: 812-283-1500 Views of Responsible Official: The Town concurs with the finding. Description of Corrective Action Plan: The Town has assigned the duties to request reimbursement (LPA Invoice Voucher) from the IN Dept of Transportation to the Office Manager of Public Works. The Office Manager will prepare the LPA Invoice Voucher for INDOT and one of the two ERC?s, Public Works Director, or Assistant Public Works Director, will review for accuracy and sign off on the LPA Invoice Voucher. Anticipated Completion Date: May 9, 2023
Finding 2022-004 ? Higher Education Emergency Relief Fund, CFDA#84.425F The University is committed to following all guidelines in the HEERF programs and will amend any quarterly or annual reports as needed. All HEERF related transactions will be reviewed for compliance before executing the drawdow...
Finding 2022-004 ? Higher Education Emergency Relief Fund, CFDA#84.425F The University is committed to following all guidelines in the HEERF programs and will amend any quarterly or annual reports as needed. All HEERF related transactions will be reviewed for compliance before executing the drawdowns or disbursements. The most recent disbursement of student funds followed a stringent process. HEERF requirements were reviewed prior to implementation between the business office and the financial aid office. Eligible students were verified by both offices. The disbursements were compiled by the controller and the amounts were put on student accounts by the director of student accounts. HEERF drawdowns were then requested from the general ledger accountant with the controller verifying the drawdowns reconciled with amount put on student accounts. Business office staff distributed the checks to students; signatures were required for pick up by the students. Responsible Parties: Eric McDonald, Interim VP of Finance and Administration emcdonald@limestone.edu 864-488-4522 Jeremy Whitaker, Associate VP of Finance and Administration jwhitaker@limestone.edu 864-488-4539
FINDING 2022-003 Subject: Staffing for Adequate Fire and Emergency Response (SAFER) Contact Person Responsible for Corrective Action: Dustin Dillard Contact Phone Number: 812-331-1906 Views of Responsible Official: We understand and agree with the importance of internal controls and segregation of d...
FINDING 2022-003 Subject: Staffing for Adequate Fire and Emergency Response (SAFER) Contact Person Responsible for Corrective Action: Dustin Dillard Contact Phone Number: 812-331-1906 Views of Responsible Official: We understand and agree with the importance of internal controls and segregation of duties at the District and we believe our policies, procedures, individual job descriptions and management oversight fulfill these necessary requirements, we intend to comply with the suggestions made by the auditing staff. Description of Corrective Action Plan: The SAFER Reimbursement Request spreadsheets are prepared by two administrative personnel who perform checks and balances on calculations, payroll reports, time-keeping reports and employee roster changes before submitting the information to the Fire Chief for review and submission. The District now requires both Administrative personnel to sign and date a cover sheet upon completion of the compilation. The Financial Administrative Assistant will reconcile the data entered into the FEMA portal by the Chief by initialing a printed copy of the dated request. Anticipated Completion Date: To be implemented with all future reimbursement requests following this date 8-23-23 More information about this finding is available in the Supplemental Report.
Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 day...
Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 days of the invoice was received.
Reference Number: 2022-004 Description: Child Nutrition Cluster ? Reporting Corrective Action Plan: The pandemic-related policies for food service reporting ended on June 30, 2022. For the 2022-23 school year, the District has re-instituted the use of IDs and student numbers to track meal purchases...
Reference Number: 2022-004 Description: Child Nutrition Cluster ? Reporting Corrective Action Plan: The pandemic-related policies for food service reporting ended on June 30, 2022. For the 2022-23 school year, the District has re-instituted the use of IDs and student numbers to track meal purchases by individual students. Reports from Skyward will be utilized and compared against claim data on a monthly basis . Anticipated Corrective Action Plan Completion Date: 9/1/2023 Contact Information: For additional information regarding this finding please contact Kevin Klimek, Director of Business Services, 414-371-6774
Financial Statement Finding Number: 2022-101 Lack of Documented Review of Reimbursement Requests Planned Corrective Action: This finding was identified during the 2020 audit which was not issued until February of 2022. Once issued, the City implemented new procedures where the Florida Public Assis...
Financial Statement Finding Number: 2022-101 Lack of Documented Review of Reimbursement Requests Planned Corrective Action: This finding was identified during the 2020 audit which was not issued until February of 2022. Once issued, the City implemented new procedures where the Florida Public Assistance website sends an email to request approval of reimbursements. The public work director and public works assistant both approve the reimbursement. The public works assistant then uploads reimbursement into Florida Public Assistance website and signs electronically for reimbursement to document review and approval by the City of the reimbursement request. Anticipated Completion Date: 09/30/2023 Responsible Contact Person: Taylor Jeffreys, Public Works Assistant
View Audit 32267 Questioned Costs: $1
Finding 34404 (2022-037)
Significant Deficiency 2022
Finding: 2022-037 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations as an overpayment to the county for reimbursement for law enforcement payroll is not an allowable use of federal ...
Finding: 2022-037 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations as an overpayment to the county for reimbursement for law enforcement payroll is not an allowable use of federal funds. The corrective action plan as follows: 1. The Office of State Treasurer will work with ND Office of Management and Budget to determine county contact information and any prior data requested to keep records consistent. 2. The Office of State Treasurer will contact the county to request support from the county supporting allowable expenditures incurred during the period beginning March 1, 2020 and ending on December 31, 2021 to offset the overpayment as stated in recommendation A on the Schedule of Federal Findings and Questioned Costs sent to the Office of State Treasurer on February 9, 2023. Contact Person: Nicole Krivoruchka Director of Finance Anticipated Completion Date: March 23, 2023
View Audit 36677 Questioned Costs: $1
Office of State Treasurer Finding: 2022-036 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations related to providing required information to subrecipients of Coronavirus Relief Funds ...
Office of State Treasurer Finding: 2022-036 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations related to providing required information to subrecipients of Coronavirus Relief Funds (CRF). Corrective action planned: 1. The Office of State Treasurer will work with ND Office of Management and Budget (OMB) to communicate to subrecipients timely and create a template for future use that includes the required information that was missed as detailed on the schedule of federal findings and questions costs. 2. The Office of State Treasurer has discussed with OMB that the information will not be recommunicated to the subrecipients as OMB has been in contact with subrecipients in guiding them to necessary information and assisting with any needs. It has been determined that communicating the information retroactively would cause more confusion and issues among the subrecipients. Contact Person: Nicole Krivoruchka Director of Finance Anticipated Completion Date September 3, 2023
a. Program Name: Administration for Children and Families Early Head Start Program: CFDA 93.600; VA Homeless Providers Grant and Per Diem Program: CFDA 64.024 b. Criteria: Failure to comply with the grant agreement?s terms and applicable regulations: The Corporation did not comply with grant compli...
a. Program Name: Administration for Children and Families Early Head Start Program: CFDA 93.600; VA Homeless Providers Grant and Per Diem Program: CFDA 64.024 b. Criteria: Failure to comply with the grant agreement?s terms and applicable regulations: The Corporation did not comply with grant compliance requirements such as timeliness of submitting reports to funding agencies and in other matters noted in licensing reviews. c. Condition: The Corporation has inconsistent performance on the submission of periodic grant reports in a timely matter. This submission pattern conflicts with grant timelines outlined in the Notice of Awards. Specifically, it was noted for two of Corporation?s major programs, Early Head Start and VA Homeless Providers Grant and Per Diem Program, that both had reports submitted outside of defined due dates. Early Head Start experienced 5 out of the 8 reports delayed and VA Grant Per Diem experienced 1 out of 2 reports delayed. The delayed reporting if uncorrected, might result in delays in the review and approval process on claim reimbursement and ability to make informed decisions about the future requirements on grant funding. Additionally, during our audit, JGD reviewed the results of all licensing reviews and noted two compliance deficiencies were indicated in the reporting period. These two citations are included for informational purposes: ? September 9, 2021 - Personnel File Review: Licensed childcare center located at 720 E. Street San Bernardino CA, which provides care and services to children 0-5 years of age. The annual licensing review resulted in two findings in personnel record documentation. o One employee file (center coordinator) did not have evidence of current CRP/First Aid training. Evidence of compliance was provided on September 15, 2021 and this deficiency was cleared. o One employee file (interim EHS Director) did not submit completed designated administrator packet for licensing within the ten-day window. The packet was submitted on September 15, 2021 and this deficiency was cleared. ? March 16, 2022 - Self-reported Incident: Licensed childcare center located at 1950 Imperial Ave, El Centro CA, which provides care and services to children 0-5 years of age. The Corporation self-reported an incident involving a child left sleeping and unattended for ten minutes in a classroom, on March 16, 2022. The Community Care Licensing investigated the self-report on June 23, 2022. Community Care Licensing determined the incident to be a deficiency for insufficient supervision ratios. The Corporation?s internal investigation identified the issue and took measures to remedy the deficiency prior to this licensing investigation and subsequent citation. Thus reducing the likelihood of recurrence and prioritizing the safety of children in the Corporation?s care. d. Response: The Corporation recognizes the importance of timely reporting as specified by the funding guidelines. The Corporation has designed and implemented policies and practices to support timely reporting to funding agencies. The Corporation is committed to submitting reports timely and will employ the necessary oversight to ensure this finding is resolved. Additionally, the Corporation continues to strive for excellence in service delivery and will continue to monitor and address any area of non-compliance both in our documentation and our practices. As noted in the licensing reports the areas of non-compliance were addressed and corrected immediately.
THE UNIVERSITY OF ALABAMA AT BIRMINGHAM RESPONSE TO THE UNIFORM GUIDANCE AUDIT The following is the University of Alabama at Birmingham?s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ending September 30, 2022. Finding 2022-001- Return of Interest Ear...
THE UNIVERSITY OF ALABAMA AT BIRMINGHAM RESPONSE TO THE UNIFORM GUIDANCE AUDIT The following is the University of Alabama at Birmingham?s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ending September 30, 2022. Finding 2022-001- Return of Interest Earned on Advance Payments Program: Research and Development Cluster Awards: Beta Blockers for the Prevention of Acute Exacerbations of COPD ? 12.420 Management understands the requirement to remit interest earned on advance payments in excess of $500 annually to the Department of Health and Human Services (HHS). Advance payment on awards are uncommon at our institution with only two such awards active during the period under audit. Management acknowledges and agrees with the finding as presented. The Grants and Contracts Department (Department) tracked the monthly interest earned on the advance payment received from the DOD. The department requested clarification from the DOD as to what constitutes ?annually?. There was no clarification provided at the time from DOD, as such the department used the fiscal year-end. During the fiscal year 2022, the award went through a request for an extension which coincided with the award end period. The department elected to hold off on remitting the earned interest until a final resolution on the award extension period was received. The award closeout process would include the remittance interest earned. The award was extended for an additional 12 months, but the interest earned was not remitted timely. The department also experienced turnover of a manager and an accountant during fiscal year 2022, both were actively involved in the maintenance of the award in question. The interest earned has since been remitted to HHS. Management notes that award will end September 29, 2023 with no option to extend. Interest earned will be tracked by the department and remitted with closeout documents. The University of Alabama at Birmingham expects to have this item completed by October 2023. For follow-up questions and information, contact Bernard Mays, University Controller at bmaysjr@uab.edu.
View Audit 32741 Questioned Costs: $1
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass through Agency: Arizona Department of Education Pass Through Number: 7AZ300AZ3 Award Period: July 1, 2021 through June 30, 2022 Repeat Finding: Yes ? 2021-004 Typ...
Federal Agency: U.S. Department of Agriculture Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.555 and 10.559 Pass through Agency: Arizona Department of Education Pass Through Number: 7AZ300AZ3 Award Period: July 1, 2021 through June 30, 2022 Repeat Finding: Yes ? 2021-004 Type of Finding: Significant deficiency in internal controls over compliance and immaterial matter of noncompliance 2022-006 Condition: The District did not maintain documentation to support proper review and approval of the monthly meal reimbursement claims. Criteria or Specific Requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with cash management compliance requirements. The District should have internal controls designed to ensure compliance with those provisions. Context: For four of four monthly meal reimbursement claims tested. Corrective Action Plan: The District will retain documentation in future years to show that monthly claims summaries are reviewed. Anticipated Completion Date: June 30, 2023 Name of Contact Person: Pam Bradford, Interim Business Manager
Finding 2022-003: Accuracy of Data Condition During compliance testing, it was identified that expense allocations related to payroll were not adequately supported. Corrective Action Plan Corrective Action Planned: The Agency, effective October 1, 2022, calculates wages to all programs as a pe...
Finding 2022-003: Accuracy of Data Condition During compliance testing, it was identified that expense allocations related to payroll were not adequately supported. Corrective Action Plan Corrective Action Planned: The Agency, effective October 1, 2022, calculates wages to all programs as a percentage. These percentages are used in the development of the budget and shared with the human resources for bi-weekly payroll. Employees paid out of multiple funds are now delineated in a spreadsheet by the Finance Director pursuant to a new standard operating procedure. The Staff Accountant enters the monthly recurring adjustment for wages. If Agency budgets are amended and wages adjusted during the fiscal year, the board in coordination with the Executive Director will notify the Finance Department. The Finance Director will then create a new recurring entry, and any adjustments, for recording for the Staff Accountant. Name of Contact Person Responsible for Corrective Action: Clint Deschene, Director Finance Anticipated Completion Date: March 2023
Finding 2022-002: Unallowable Costs Condition The Agency must submit only expense allowable costs for reimbursement under the accounting and the cost accounting principles contained in Uniform Guidance. Corrective Action Plan Corrective Action Planned: In January 2022 the Agency was deemed tax...
Finding 2022-002: Unallowable Costs Condition The Agency must submit only expense allowable costs for reimbursement under the accounting and the cost accounting principles contained in Uniform Guidance. Corrective Action Plan Corrective Action Planned: In January 2022 the Agency was deemed tax exempt for State Sales Tax. The new Finance Director has already met with the Executive Director and Leadership concerning this finding. Purchasing is working to eliminate reimbursements of taxed purchases and creating agency accounts with vendors for these orders. The Agency is also updating all internal procedures and leadership is being trained to prevent further occurrences. Name of Contact Person Responsible for Corrective Action: Clint Deschene, Director Finance Anticipated Completion Date: March 2023
Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan...
Contact Person Responsible for Corrective Action: Brian Leitch, Chief Finance & Operations Officer / Treasurer 260-347-2502 ext.: 10017 Roger Urick, Interim Food Service Director 260-347-2502 ext.: 10011 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal Controls: The monthly meal reimbursement claims will be calculated by the Food Service Director by using information obtained through meal magic. Once the meal reimbursement is calculated it will be reviewed by the Deputy Treasurer before being submitted by the Food Service Director. Once the reimbursement is received the Deputy Treasurer will verify it was received as submitted. Anticipated Completion Date: April 2023
U.S. Department of Agriculture Finding 2022-001: MATERIAL WEAKNESS?Recording of Food Service Claims Activity Pass-through entity: Michigan Department of Education Award Numbers: COVID-19 221971 and COVID-19 221961 Award Year End: September 30, 2022 Recommendation: The School District shoul...
U.S. Department of Agriculture Finding 2022-001: MATERIAL WEAKNESS?Recording of Food Service Claims Activity Pass-through entity: Michigan Department of Education Award Numbers: COVID-19 221971 and COVID-19 221961 Award Year End: September 30, 2022 Recommendation: The School District should recognize the monthly food service activity in the accounting records following the submission of the claims reports to the State of Michigan. Action Taken: After submitting the monthly food service claims reports for reimbursement, the Director of Finance provides a copy of the claims report to the Accounting Manager to record the corresponding activity and to compare it to the amount of the subsequent deposit. Responsible Person and Completion Date: Director of Finance, February 2022 If the Michigan Department of Education has questions regarding this plan, please call Tracey French at (231) 744-4736.
Finding 2022-002: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 10.553, 10.555 and 10.559 Award Numbers: COVID-19 211971, COVID-19 221970, COVID-19 221971, COVID-19 211961, COVID-19 220910, COVID-19 221...
Finding 2022-002: Child Nutrition Cluster Resource Management Procedures Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 10.553, 10.555 and 10.559 Award Numbers: COVID-19 211971, COVID-19 221970, COVID-19 221971, COVID-19 211961, COVID-19 220910, COVID-19 221960, COVID-19 221961, COVID-19 210904 and Entitlement Commodities Award Year Ends: June 30, 2022 Recommendation: The School District should develop and complete a spend-down plan to ensure it reduces its Food Service Fund net cash resources below the maximum allowable amount. Action Taken: The School District has started to develop a spend-down plan that it will implement and complete in the fiscal year ending June 30, 2023. Responsible Person and Anticipated Completion Date: The Superintendent is responsible for the development and execution of the spend-down plan with a completion date of June 30, 2023. If the Michigan Department of Education has questions regarding this plan, please call Mark Platt at (231) 873-6224.
Finding Number: 2022-006 ? Approval of Expense Reimbursement Submittals Corrective Action Plan: All expense reimbursements should be approved in writing. The findings occurred at a time when Academica Nevada was shorthanded. Since that time all open positions have been filled. Grant managers send...
Finding Number: 2022-006 ? Approval of Expense Reimbursement Submittals Corrective Action Plan: All expense reimbursements should be approved in writing. The findings occurred at a time when Academica Nevada was shorthanded. Since that time all open positions have been filled. Grant managers send a request for approval for reimbursement to the applicable school. Approval is in writing, typically via email, prior to the submittal of the reimbursement request. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2023
Finding 2022-002: Insufficient Review and Approval of Federal Grant Expenditures Person(s) Responsible for Implementing the Corrective Action: Tam Jaramillo, Chief Financial Officer Corrective Action Planned: Additional oversight by a member of senior management is provided for any future requests. ...
Finding 2022-002: Insufficient Review and Approval of Federal Grant Expenditures Person(s) Responsible for Implementing the Corrective Action: Tam Jaramillo, Chief Financial Officer Corrective Action Planned: Additional oversight by a member of senior management is provided for any future requests. Anticipated Completion Date of Corrective Action: Management will implement the corrective actions during 2023. Tam
Our response: UPCEE has hired a Contract Manager. This person recently retired as the Director of Contracts from a four-year emerging research institution. They come highly skilled in working with federal granting agencies. ? They will oversee office management processes, budgets, and enhance ou...
Our response: UPCEE has hired a Contract Manager. This person recently retired as the Director of Contracts from a four-year emerging research institution. They come highly skilled in working with federal granting agencies. ? They will oversee office management processes, budgets, and enhance our current way of working with federal timelines. ? They will ensure billings are kept timely and entered into our financial system of QuickBooks to better serve annual audit engagement and reporting requirements. Additionally, ? UPCEE drawdowns will be scheduled and done bi-monthly effective June 2023. UPCEE reserve the right to deviate for special events and give notice to program manager beforehand. ? The Contract Manager will generate payable documents that now will have the certifying official approve before requesting funds in G-5. With the implementation of these new processes, UPCEE feels very confident that this will prevent any further need for risk management.
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