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Finding 2023-001: Restatement to Fund Balance Condition: During audit fieldwork, our testing resulted in a restatement of fund balance to correct prior year accruals and deferrals related to property taxes, accounts payable, grant receivables, etc. that were not included on the unadjusted trial bala...
Finding 2023-001: Restatement to Fund Balance Condition: During audit fieldwork, our testing resulted in a restatement of fund balance to correct prior year accruals and deferrals related to property taxes, accounts payable, grant receivables, etc. that were not included on the unadjusted trial balances Plan: The City will implement internal controls to properly record necessary accruals and deferrals on a timely basis prior to audit fieldwork. Additionally, the City Comptroller should provide monthly reviews of the financial statements Anticipated Date of Completion: Fiscal Year Ending April 30, 2024
Finding 485981 (2023-002)
Significant Deficiency 2023
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2023-002 (repeat finding of 2022-001) Continuum of Care Program, ALN #14.267 Auditor’s Recommendation: We recommend that when a check is paid, the expense is allocated through the accounting system. At the time a grant voucher is prepared, only actual expe...
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2023-002 (repeat finding of 2022-001) Continuum of Care Program, ALN #14.267 Auditor’s Recommendation: We recommend that when a check is paid, the expense is allocated through the accounting system. At the time a grant voucher is prepared, only actual expenses should be requested. We recommend that each reimbursement request agrees to what is allocated through the accounting system by grant or program for actual expenses. This will help support the request and, if needed, a method to provide the actual invoice for the expense being requested. Action Taken: Supportive Strategies has set up cost centers so all Grant vouchers/expenses are allocated to the proper Grant.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-004 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.308, all budget revisions over 10% must receive a budget revision from the grantee. Condition: Following a budget revision of over 10%, an approval was not rece...
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-004 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.308, all budget revisions over 10% must receive a budget revision from the grantee. Condition: Following a budget revision of over 10%, an approval was not received from the grantee. Cause: At direction from the pass-through agency, the Organization charged salary expenses to the contract services line items on its request reimbursement instead of getting budget revisions to reflect the change in the work performed. Effect: The costs billed on the vouchers for reimbursement, did not match the natural classification of the actual expenses incurred on the grant resulting in expenses reported being over budget on certain line items and under budget on others Auditor recommendation: We recommend that when there is a budget revision over 10%, the Organization works with the grantor to get formal documentation to support the revision to ensure amounts charged to the grants are in line with budget line items. Management response: Management will ensure a budget revision be done for any increase over 10% and submit that to the grantor to receive formal approval from the grantor.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.305(b)(3), all reimbursement requests should be based on supporting documentation that shows the cost was incurred before the request for payment and that the p...
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.305(b)(3), all reimbursement requests should be based on supporting documentation that shows the cost was incurred before the request for payment and that the payment to vendor was made. Condition: 4 of the 7 cash drawdown reports tested contained expense reimbursements requested for which there was missing supporting documentation for some of the expenses requested for reimbursements. Total questioned costs were $115,617. Cause: The extra expenses that were missing in the test were because IAFP used staff instead of consultants and the Organization did not update our policies and procedures to include time sheets to show how staff was allocated to the grant to support the charges. Effect: The effect is that the Organization requested funds but did not have back up to support that the actual expenses were incurred and was therefore not in compliance with the cash management requirements under Uniform Grant Guidance in relation reimbursement requests. Auditor recommendation: We recommend that the accounting department verify that the expense has been incurred and paid to the vendor before requesting reimbursement from the grantor and ensure that the backup documentation is filed where it can be located. We recommend hiring or training staff in relation to cash management and documentation of allowable cost. Management response: Management will follow the advice and undergo training in cash management and documentation of allowable costs.
Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Nebraska Emergency Management Agency Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: There was one instance of an employee’s timesheet which was reviewed an...
Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Nebraska Emergency Management Agency Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: There was one instance of an employee’s timesheet which was reviewed and approved by the same employee and did not have an independent review performed. Responsible Individuals: Carmen Christensen, CFO/Office Manager Corrective Action Plan: The employee who reviews the timesheet is the general foreman. Action has been taken and all general foreman time will be approved electronically by the Operations Manager once training has been completed on entering time in the software system. Anticipated Completion Date: October 1, 2024
Finding 485752 (2023-001)
Significant Deficiency 2023
Finding Reference Number: 2023-001 Description of Finding: During our audit for the year ended December 31, 2023, we inquired and requested documentation regarding the repayment status of the Flexible Subsidy Loan from the Agency's officers and from its management company. The Agency did not have do...
Finding Reference Number: 2023-001 Description of Finding: During our audit for the year ended December 31, 2023, we inquired and requested documentation regarding the repayment status of the Flexible Subsidy Loan from the Agency's officers and from its management company. The Agency did not have documentation regarding the mortgage status of the Flexible Subsidy Loan available since the HUD Section 202 mortgage was paid off in November 2016. Statement of Concurrence or Nonconcurrence: We are in agreement with this finding. Corrective Action: King's Daughters and Sons Management Company, Pilgrim Towers' new management agent as of 4/1/2024, has engaged with HUD's Northeast Multifamily Asset Resolution Specialist Branch to explore any statutory or regulatory options for loan deferral as part of a preservation transaction. These conversations are ongoing and a DRAFT proposal for loan deferral under HUD Notice 2011-05 has been submitted to that division. Name of Contact Person: Pat Thatcher, Board Treasurer patthatcher1@gmail.com 203-451-1090 Projected Completion Date: Anticipated to be competed in 2024.
We have processes in place to account for these requirements, but in this case the year end changed, and a stub period audit was conducted. We could not make a deposit by 10/31/23 since we did not have the final audit by then and there were not sufficient funds in the operating account to cover the ...
We have processes in place to account for these requirements, but in this case the year end changed, and a stub period audit was conducted. We could not make a deposit by 10/31/23 since we did not have the final audit by then and there were not sufficient funds in the operating account to cover the funding. Going forward, management will ensure that any shortage is funded on time even if operating funds are short and we have to request funds from ownership.
Finding 485719 (2023-001)
Significant Deficiency 2023
We have processes in place to account for these requirements, but in this case the year end changed, and a stub period audit was conducted. We could not make a deposit by 10/31/23 since we did not have the final audit by then and there were not sufficient funds in the operating account to cover the ...
We have processes in place to account for these requirements, but in this case the year end changed, and a stub period audit was conducted. We could not make a deposit by 10/31/23 since we did not have the final audit by then and there were not sufficient funds in the operating account to cover the funding. Going forward, management will ensure that any shortage is funded on time even if operating funds are short and we have to request funds from ownership.
Ineffective Controls Over the Cash Management Requirement Condition Community Health Concern, Inc. (“CHC”) did not minimize the times between drawdowns and disbursements of Federal funds in accordance with Federal regulations. There were three cash drawdowns made by management that were at least tw...
Ineffective Controls Over the Cash Management Requirement Condition Community Health Concern, Inc. (“CHC”) did not minimize the times between drawdowns and disbursements of Federal funds in accordance with Federal regulations. There were three cash drawdowns made by management that were at least two months (60 days) in advance of actual expenditures or immediate requirement needed for payment. Management’s Views: Management concurs with the audit findings and will implement various steps that will strengthen our internal control processes to mitigate any potential cash drawdown noncompliance in the future. Corrective Action Plan: In response to the Cash Management finding, the following actions will be implemented to ensure compliance with federal grant guidelines and to maintain transparency and accountability, CHC will: 1. Seek HRSA Guidance • In situations that are out of the ordinary or not explicitly covered by existing grant guidelines, the Director of Finance or his/her designee will seek guidance from the Health Resources and Services Administration (HRSA). • This step ensures that all actions taken are compliant with HRSA’s grant guidelines, 2. Consult the External Auditor • For additional guidance and to ensure proper procedure, the Director of Finance or his/her designee will consult with the external auditor. • If HRSA guidance is available, it will be shared with the external auditor to confirm that all steps align with federal requirements and best practices. 3. Continually Communicate and Engage with the Finance Committee and the Board of Directors • Ongoing communication and engagement with the Finance Committee and the Board of Directors will be maintained. • Regular updates will be provided on the status of grant fund requests, drawdowns, and any guidance received from HRSA or the external auditor. • This practice ensures that the Finance Committee and the Board of Directors are fully informed and can provide oversight and support as needed. Anticipated Date of Completion: Management has implemented approximately 85% of the strategies described in the Plan above. Management believes by implementing these actions, the compliance with federal grant guidelines will be enhanced to ensure transparency to the financial operations as well as maintain robust oversight by involving key stakeholders in the process. Management anticipates the successful completion date for the entire Plan to be no later than August 31st, 2024. Contact Person: For inquiries regarding this finding, please contact Benjo Reyes at BenjoR@CamillusHealth.org who is responsible for the corrective actions.
View Audit 318513 Questioned Costs: $1
Corrective Action: CBNHC will implement the following corrective actions: • The CBNHC Board of Directors will consult with both the CEO and the Finance Director to ensure that board actions for premium payroll disbursements are allowable and comply with 2 CFR Part 200. • CBNHC will immediately init...
Corrective Action: CBNHC will implement the following corrective actions: • The CBNHC Board of Directors will consult with both the CEO and the Finance Director to ensure that board actions for premium payroll disbursements are allowable and comply with 2 CFR Part 200. • CBNHC will immediately initiate a collection notice to the Board of Directors who received the “essential worker” payments in fiscal year 2023. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Board of Directors (Kimberly Bruce, Lester Secatero, Harrison Platero) – Are responsible for CBNHC’s governance and will monitor compliance with 2 CFR Part 200. • Interim Finance Director/Chief Operations Officer (Volelle Zamora) through the Chief Executive Officer (Derrick Watchman) – Are responsible for issuing a notice of collections to the Board of Directors who received the premium payments in fiscal year 2023. Completion Date: CBNHC will immediately issue collection notices and will coordinate the accounting for the repayment of the unallowable costs.
View Audit 318493 Questioned Costs: $1
Condition: The District did not claim expenditures in conformity with the approved detail budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: June 30, 2024. Name of Contact Perso...
Condition: The District did not claim expenditures in conformity with the approved detail budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: June 30, 2024. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: Management will work together with staff to ensure that grant budgets are periodically reviewed and amended as necessary.
View Audit 318405 Questioned Costs: $1
The finding from Section III – Activities Allowed or Unallowed Finding 2023-004 – General Ledger System Condition: Federal expenditures should be posted to the federal funding source accounts in the general ledger as they are incurred, and significant adjusting entries reclassing expenditures shoul...
The finding from Section III – Activities Allowed or Unallowed Finding 2023-004 – General Ledger System Condition: Federal expenditures should be posted to the federal funding source accounts in the general ledger as they are incurred, and significant adjusting entries reclassing expenditures should be at a minimum. This will allow for the proper reporting of the eligible amounts to claim for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager is aware and responsible for appropriate reporting of expenditures related to federal funding. During the course of the 2022-2023 school year, appropriate processes and classifying of expenditures were not completed as they should have been, resulting in numerous after-closing journal entries to correct the issues. Moving forward, with the assistance and guidance of federal and state guidelines, all expenditures will be budgeted for within the grant application and reconciled with the district’s general ledger, to ensure proper allocations. Additionally, reporting that is to be done quarterly will also verify the placement of expenditures accurately. The person responsible for the corrective action plan will be the Business Manager and the anticipated completion date will be June 30, 2024, but no later than June 30, 2025 due to the delays that occurred in the completion of the audit ending June 30, 2023.
The finding from Section III – Federal Awards Findings and Questioned Costs Finding 2023-002 – Cash Management and Reporting Condition: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. The...
The finding from Section III – Federal Awards Findings and Questioned Costs Finding 2023-002 – Cash Management and Reporting Condition: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires annual final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after the funds are expended but no later than 30 days after the ending of the date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager will work directly with the District Superintendent and the Federal Programs Coordinator, as well as any additional parties involved in the process of the Federal Grants filing the expenditure reports quarterly and filing of the final expenditure reports. Procedures will include creating reminders on the Business Manager’s calendars that include the due dates each quarter, reporting the appropriate expenditures in the accounting software, and creating a separate report listing the expenditures for that quarter and the remaining funds for future quarters. Account numbers that accurately reflect and represent the expenditures for related funding sources will be created and reviewed for necessary changes as the projects progress.
Assistance Listing Number: 84.425F Program Name: COVID-19: HEERF – Institutional Portion Pass Through Identifying Number: N/A Award Year: 2022-2023 Federal Agency: U.S. Department of Education Management agrees with the findings and, as discussed, the College is currently searching for a candidate t...
Assistance Listing Number: 84.425F Program Name: COVID-19: HEERF – Institutional Portion Pass Through Identifying Number: N/A Award Year: 2022-2023 Federal Agency: U.S. Department of Education Management agrees with the findings and, as discussed, the College is currently searching for a candidate to fulfill the CFO position with the appropriate level of training. The College does intend to interview accounting professionals from the community to determine if appropriate levels are present. Responsible Party: Dr. Justin Hoggard, Board President and Dixie Lytle, Director of Human Resources Expected Completion: December 31, 2024 Anticipated Completion: December 31, 2024
Corrective Action: Monroe County Schools will take the following corrective actions to improve the activities allowed/unallowed – ESSER: • The Board will reimburse the ESSER program for the noncompliant expenditure and ensure future expenditures meet the federal requirements for ESSER program fundin...
Corrective Action: Monroe County Schools will take the following corrective actions to improve the activities allowed/unallowed – ESSER: • The Board will reimburse the ESSER program for the noncompliant expenditure and ensure future expenditures meet the federal requirements for ESSER program funding. • The Federal Programs Director and the new CSBO will be required to review 2 CFR 200 to develop an understanding of applicable expenditures incurred with federal funds. • The Federal Programs Director will be responsible for ensuring all federal expenses are allowable under the grant according to CFR 200. • The new CSBO will review federal expenses to ensure they are allowable under the grant according to CFR 200. Effective Date: September 30, 2024 Person(s) Responsible: CSBO and Director of Federal Programs, Monroe County Schools
Statement of Condition #2023-001 (CFDA 14.157): During the year ended December 31, 2023, the Corporation made a payment on the CRA loan of $1,157 without HUD approval. Recommendation: Management should submit a residual receipts request to HUD for the withdrawal in the amount of $1,157. In the futu...
Statement of Condition #2023-001 (CFDA 14.157): During the year ended December 31, 2023, the Corporation made a payment on the CRA loan of $1,157 without HUD approval. Recommendation: Management should submit a residual receipts request to HUD for the withdrawal in the amount of $1,157. In the future, management should obtain approval from HUD before making any payments on the CRA loan. Action(s) taken or planned on the finding: Management concurs with the finding and will submit a residual receipts withdrawal request in the amount of $1,157 during the year ended December 31, 2024.
View Audit 318198 Questioned Costs: $1
Plan: The Village will implement internal controls to properly record property tax revenue, receivables, and deferred on a timely basis prior to audit fieldwork. Additionally, the Village Finance Director will provide monthly reviews of the financial statements.
Plan: The Village will implement internal controls to properly record property tax revenue, receivables, and deferred on a timely basis prior to audit fieldwork. Additionally, the Village Finance Director will provide monthly reviews of the financial statements.
Finding 485396 (2023-001)
Significant Deficiency 2023
CORRECTIVE ACTION PLAN Name and Number of the Project: Cushing Housing, Inc. No. 117-11093 Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regard...
CORRECTIVE ACTION PLAN Name and Number of the Project: Cushing Housing, Inc. No. 117-11093 Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 1: HUD Guaranteed 223(a)(7) Mortgage 14.135 CORRECTIVE ACTION COMPLETED: Within 60 days of 2022 year end, the Company had expended any surplus cash on the operations of the property and the funds were no longer available. Management is in contact with HUD to find a resolution to the finding. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Jimmy K. Arnold, President, Arnold Grounds Apartment Management & Affordable Housing Specialists.
2023-006 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports for first and second quarter of 2023 were not f...
2023-006 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports for first and second quarter of 2023 were not filed. However, these reports were filed for the third and fourth quarter of 2023. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Auditor Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. Corrective Action. City staff has accessed these reports and attempted to submit all required reports. Ongoing reports have been submitted on time. Assistance will be sought with federal agencies as necessary. Responsible Person. City Manager Anticipated Completion Date. December 31, 2024
Finding 485273 (2023-002)
Significant Deficiency 2023
Select Board and School Committee will adopt any required written policies and procedures under Uniform Guidance. Select Board and School Committee will formally adopt written policies and procedures under Uniform Guidance by September 30, 2024
Select Board and School Committee will adopt any required written policies and procedures under Uniform Guidance. Select Board and School Committee will formally adopt written policies and procedures under Uniform Guidance by September 30, 2024
When the new director, Robert Weismore, was hired on September 7, 2022, he replaced the former director and 3 staff members. In October he hired the current staff of Ms. Schaefer, Ms. Lynn. Ms. Filipski was hired as a part time employee in the middle of September 2022. For the next 2 months the staf...
When the new director, Robert Weismore, was hired on September 7, 2022, he replaced the former director and 3 staff members. In October he hired the current staff of Ms. Schaefer, Ms. Lynn. Ms. Filipski was hired as a part time employee in the middle of September 2022. For the next 2 months the staff reviewed each file and recalculated the figures using the correct payment standards for the necessary period and also used the September 1, 2022 approved utility schedule installed by the current staff. The recalculations caused the North Syracuse Housing Authority to reimburse $25,463 to previously miscalculated tenants. Also, had to repa HUD $23,000. The current payment standards are up to date and the current utility schedule was updated effective 7/1/2023 and will be updated effective 7/1/24 and each July thereafter.
Please see 2020-008 regarding payment standards and utility schedules. The current staff updated the current rent reasonableness comparisons during the summer of 2023. This was accomplished by completing a survey of area wide rents and amenities for comparable units. Each folder has a rent reasonabl...
Please see 2020-008 regarding payment standards and utility schedules. The current staff updated the current rent reasonableness comparisons during the summer of 2023. This was accomplished by completing a survey of area wide rents and amenities for comparable units. Each folder has a rent reasonableness form showing the comparables and justifying the rent being changed is eligible and within reason.
Effective 11/1/2022 all recommendations are completed with up to 90 days notice to prospective tenant, with notification as the proper verification needed to complete the recert to completion. Notification is also sent to the owner of the recertification. Once the proper verification is completed ca...
Effective 11/1/2022 all recommendations are completed with up to 90 days notice to prospective tenant, with notification as the proper verification needed to complete the recert to completion. Notification is also sent to the owner of the recertification. Once the proper verification is completed calculations are completed the tenant and owner are mailed an addendum starting new rental breakdown. The new current staff has between 10 and 15 years' experience completing recertifications. Please see item 2020-008 regarding utilities and payment standards.
Audit Period: December 31, 2023 2023-001 Missing voucher documentation, U.S. Department of Labor Criteria: Internal controls over Federal awards must be designed and implemented to provide reasonable assurance of compliance with applicable Federal statutes, regulations, and the terms and conditions ...
Audit Period: December 31, 2023 2023-001 Missing voucher documentation, U.S. Department of Labor Criteria: Internal controls over Federal awards must be designed and implemented to provide reasonable assurance of compliance with applicable Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted one instance, in a sample of 68 expenditures tested, in which supporting documentation could not be provided. Action Taken: Finance staff reviewed internal controls and the overall process with team members responsible for providing supporting documentation for all expenditures as well as those who receive and review documentation prior to processing expenses for reimbursement. In addition to this training, additional review for all supporting documents has been added prior to billing for expenses. Responsible Party: Accountant responsible for billing expenditures Point of Contact: Stephanie Smoot – VP of Finance – ssmoot@goodwillvalleys.com. Expected date of correction: End of May 2024 once made aware of missing documentation.
Finding 485115 (2023-001)
Material Weakness 2023
2023-001 CASH MANAGEMENT Recommendation: The IRL Council should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings. Management’s Response: Initial discussions with EPA staff regarding fiscal management of the funds...
2023-001 CASH MANAGEMENT Recommendation: The IRL Council should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings. Management’s Response: Initial discussions with EPA staff regarding fiscal management of the funds from the Bipartisan Infrastructure Law (BIL) suggested that management of the cash for the BIL award was different than the Section 320 grant award. During these discussions, cash flow was brought up as a possible concern by IRL Council staff. EPA staff initially indicated that the grant funds were not reimbursable and that all funds would be available as soon as an award was made. The Council was not made aware that the RAIN polices would be in effect for BIL funds. The Council interpreted EPA correspondences as authorization to withdraw funds immediately upon receiving the award. Upon making the draw, EPA provided the IRL Council with clarifying information with regards to the RAIN policy. The IRL Council responded quickly to this new information and the appropriate amount of funds were returned in a timely manner. The EPA was satis􀀁ied with the corrective response and outcome. The IRL Council will continue to manage all EPA federal grants as a reimbursable grant award to ensure the RAIN policy is followed correctly. For any other Federal agency grants that may be awarded, strict adherence to that agency’s policies for treasury draws will be made. Responsible Party: Daniel Kolodny, Chief Operating Officer
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