Corrective Action Plans

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Strengthened record retention practices to ensure documentation of internal control activities is preserved in accordance with 2 CFR 200.334 (three years from submission of final expenditure report) by February 28, 2026. Implemented procedures to maintain institutional knowledge during employee turn...
Strengthened record retention practices to ensure documentation of internal control activities is preserved in accordance with 2 CFR 200.334 (three years from submission of final expenditure report) by February 28, 2026. Implemented procedures to maintain institutional knowledge during employee turnover, including documented policies, cross-training, centralized recordkeeping, and formal transition protocols by March 31, 2026. Extended retention periods for documents supporting high-risk federal programs or key internal control activities beyond minimum requirements by April 30, 2026. Established a centralized electronic filing system with version control and backup procedures for all federal award documentation by May 31, 2026. Created detailed internal control documentation templates and ensure all control activities are evidenced in writing by June 30, 2026.
FINDING: 2023-006: ESSER Allowable Costs (Payroll Disbursements) CONTACT PERSON: Jatana Norris CORRECTIVE ACTION: The School District will ensure sufficient documentation of time and effort is obtained in the future. PROPOSED COMPLETION DATE: Ongoing
FINDING: 2023-006: ESSER Allowable Costs (Payroll Disbursements) CONTACT PERSON: Jatana Norris CORRECTIVE ACTION: The School District will ensure sufficient documentation of time and effort is obtained in the future. PROPOSED COMPLETION DATE: Ongoing
FINDING: 2023-005: Title I Allowable Costs (Payroll Disbursements) CONTACT PERSON: Jatana Norris CORRECTIVE ACTION: The School District will ensure sufficient documentation of time and effort is obtained in the future. PROPOSED COMPLETION DATE: Ongoing
FINDING: 2023-005: Title I Allowable Costs (Payroll Disbursements) CONTACT PERSON: Jatana Norris CORRECTIVE ACTION: The School District will ensure sufficient documentation of time and effort is obtained in the future. PROPOSED COMPLETION DATE: Ongoing
Audit Finding Reference: 2023-003 Timely Filing of Single Audit Report Planned Corrective Action: Require faster completion by audit firm Planned Implementation Date of Corrective Action: Immediately upon notification, June 09, 2025. Person Responsible for Corrective Action: County Administrator and...
Audit Finding Reference: 2023-003 Timely Filing of Single Audit Report Planned Corrective Action: Require faster completion by audit firm Planned Implementation Date of Corrective Action: Immediately upon notification, June 09, 2025. Person Responsible for Corrective Action: County Administrator and Finance Director
Audit Finding Reference: 2023-002 Internal Controls Over Reporting Planned Corrective Action: Finance Director will review quarterly report prior to submission Planned Implementation Date of Corrective Action: Immediately upon notification, June 09, 2025. Person Responsible for Corrective Action: Co...
Audit Finding Reference: 2023-002 Internal Controls Over Reporting Planned Corrective Action: Finance Director will review quarterly report prior to submission Planned Implementation Date of Corrective Action: Immediately upon notification, June 09, 2025. Person Responsible for Corrective Action: County Administrator and Finance Director
Management agrees with this finding and acknowledges the seriousness of the reported material weakness and material noncompliance related to equipment management for federally funded assets. To remediate this finding, the Fund will establish a comprehensive, centralized fixed asset and equipment reg...
Management agrees with this finding and acknowledges the seriousness of the reported material weakness and material noncompliance related to equipment management for federally funded assets. To remediate this finding, the Fund will establish a comprehensive, centralized fixed asset and equipment register that specifically identifies federally funded equipment and links each applicable asset to the related federal award information. The register will include, where applicable, asset description, serial number or other identifying number, acquisition date, acquisition cost, percentage of federal participation, award identification, location, use, condition, inventory date, and disposition data. Management will also conduct a full physical inventory to establish a verified baseline and implement recurring inventory procedures at least every two years. Corrective action plan: • Create a centralized equipment register for all federally funded equipment and cross-reference each asset to the related federal program, award year, and other available grant or assistance documentation. • Perform a complete physical inventory of federally funded equipment to establish a baseline inventory and validate existence, location, condition, and identifying information. • Reconcile the physical inventory results to accounting records and the centralized register, and research all variances. • Implement procedures for timely recording of acquisitions, transfers, impairments, disposals, and retirements, including retention of supporting documentation. • Adopt written equipment management procedures addressing safeguarding, tagging where practical, periodic review, disposition approvals, and compliance monitoring. • Schedule recurring physical inventories at least every two years, with interim updates for additions, disposals, and transfers performed throughout the year. Responsible party/role: Business Office Manager and in coordination with Operations/Network Management and oversight by the General Manager. Implementation timeline: The centralized federally funded equipment register will be established within 90 days of issuance of the audit report. The initial full physical inventory and reconciliation will be completed by June 30, 2026. The recurring inventory cycle will be formally scheduled upon completion of the baseline inventory and performed at least every two years thereafter. Management further intends to monitor compliance with federal equipment management requirements as part of its ongoing grant and award administration process. Where historical federal award information is incomplete, management will work from available accounting records, grant files, procurement records, and other supporting documentation to reconstruct asset history to the extent practicable.
Management agrees with this finding. The Fund has historically relied on independent auditors to assist with drafting the annual financial statements and note disclosures in accordance with GAAP due to limited internal accounting resources. While management expects to continue relying on the auditor...
Management agrees with this finding. The Fund has historically relied on independent auditors to assist with drafting the annual financial statements and note disclosures in accordance with GAAP due to limited internal accounting resources. While management expects to continue relying on the auditors for drafting assistance in the near term, management will strengthen its internal review and approval process over financial reporting. This will include additional training for accounting personnel and management, use of financial statement disclosure checklists, and more formal review by management and those charged with governance before issuance. Corrective action plan: • Designate a member of management to serve as the internal financial reporting coordinator for the annual audit and reporting process. • Obtain training for accounting and management personnel on GAAP financial statement presentation, note disclosure requirements, and key year-end reporting areas relevant to the Fund. • Use an annual financial statement review checklist to evaluate the draft statements, note disclosures, and required supplementary information, if any. • Require documented management review and approval of the final financial statements and related notes before issuance. • Provide the Board of Directors or designated governance committee with an opportunity to review the audited financial statements and significant disclosures. Responsible party/role: General Manager and Business Office Manager, with governance oversight by the Board of Directors. Implementation timeline: The enhanced review process will be implemented for the next annual financial reporting cycle and no later than the preparation of the financial statements for the year ending September 30, 2026. Training and checklist development will occur by June 30, 2026.
Management agrees with this finding. Management acknowledges that the Fund’s existing property records have not been sufficiently centralized or detailed to support strong control over capital assets, depreciation, and asset lifecycle monitoring. The Fund will create a centralized fixed asset regist...
Management agrees with this finding. Management acknowledges that the Fund’s existing property records have not been sufficiently centralized or detailed to support strong control over capital assets, depreciation, and asset lifecycle monitoring. The Fund will create a centralized fixed asset register that includes, at a minimum, asset description, asset tag or identifier, acquisition date, placed-in-service date, cost, funding source where applicable, depreciation method, useful life, physical location, condition, custodian or department, and disposal information. Management will also reconcile the register to the general ledger on a periodic basis and formalize policies governing capitalization thresholds, depreciation, transfers, retirements, and write-offs. Corrective action plan: • Develop and populate a centralized fixed asset register for all significant capital assets. • Perform a baseline review of existing capital asset balances and supporting invoices, contracts, and prior schedules to establish completeness. • Reconcile the fixed asset register to the general ledger and investigate differences. • Adopt a written capital asset policy addressing capitalization thresholds, useful lives, depreciation conventions, disposals, and approval requirements. • Perform a physical inventory of capital assets and update records for location, condition, and disposition status. Responsible party/role: Staff Accountant in coordination with the Business Office Manager and oversight from the General Manager. Implementation timeline: The centralized fixed asset register will be established within 120 days of issuance of the audit report. The initial reconciliation to the general ledger and baseline physical inventory will be completed by June 30, 2026, with periodic reconciliations performed thereafter at least quarterly for additions and disposals and annually for full rollforward validation.
Management agrees with this finding. Management acknowledges that balance sheet reconciliations were not performed or reviewed with sufficient consistency and documentation, which increases the risk that errors, omissions, or unauthorized activity may not be identified on a timely basis. Management ...
Management agrees with this finding. Management acknowledges that balance sheet reconciliations were not performed or reviewed with sufficient consistency and documentation, which increases the risk that errors, omissions, or unauthorized activity may not be identified on a timely basis. Management will implement a formal reconciliation process for significant balance sheet accounts, including cash, receivables, payables, debt, accrued liabilities, intercompany or related-party balances if applicable, and other key accounts. Reconciliations will be prepared on a documented monthly or quarterly basis depending on account risk and volume, independently reviewed, and retained in a centralized file. Reconciling items will be investigated and resolved within an established deadline, except where a longer period is justified and documented. Corrective action plan: • Adopt a reconciliation policy identifying each significant balance sheet account, frequency of reconciliation, preparer, reviewer, and required supporting documentation. • Prepare monthly reconciliations for cash, major receivables, major payables, payroll liabilities, and debt accounts; prepare quarterly reconciliations for lower-risk or less active balance sheet accounts. • Require independent review and sign-off by the Finance Manager/Controller or General Manager, as appropriate. • Retain all reconciliation workpapers and supporting schedules in an organized electronic and/or paper file. • Establish a requirement that routine reconciling items be cleared within 30 days after identification, and no later than the subsequent monthly close absent documented management approval. Responsible party/role: Staff Accountant or Bookkeeper as preparer; Business Office Manager as primary reviewer; General Manager for oversight. Implementation timeline: Reconciliation templates and the formal policy will be implemented within 60 days of issuance of the audit report. Full documented monthly and quarterly reconciliations will begin with the next monthly close thereafter, and all significant balance sheet accounts are expected to be covered by September 30, 2026.
Management agrees with this finding. Because the Fund operates with a relatively small administrative staff, complete segregation of incompatible duties is not always feasible. Management and those charged with governance recognize this as an inherent limitation of the current organizational structu...
Management agrees with this finding. Because the Fund operates with a relatively small administrative staff, complete segregation of incompatible duties is not always feasible. Management and those charged with governance recognize this as an inherent limitation of the current organizational structure rather than an intentional departure from sound control practices. To address this limitation, the Fund will strengthen compensating oversight controls. These measures will include increased review of disbursements, bank activity, journal entries, and selected account activity by senior management and periodic reporting to the Board of Directors or its designated governance committee. Existing mitigating controls include management familiarity with operations, review of significant cash disbursements, and governance oversight at regular meetings; however, these controls will be formalized and documented more consistently. Corrective action plan: • Implement a documented monthly review of cash disbursements, bank statements, journal entries, and unusual transactions by the General Manager or equivalent executive not performing day-to-day bookkeeping functions. • Require Board of Directors or finance committee review of summarized financial information, check registers, and budget-to-actual results at regular meetings. • Establish approval thresholds requiring dual review for significant non-routine disbursements, vendor additions, write-offs, and manual journal entries. • Document evidence of supervisory review through sign-off or electronic approval retention. Responsible party/role: General Manager, Business Office Manager, Staff Accountant, and Board of Directors. Implementation timeline: Initial compensating control procedures will be implemented within 90 days of issuance of the audit report, with board-level reporting enhancements in place by June 30, 2026.
VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written proces...
VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written process in accordance with both state and federal regulations. We will prepare written process in accordance with both state and federal regulations. We will require relevant staff (Staff interacting with procurement, expenditures approval) a comprehensive training program on the requirements of CFR 200. IMPLEMENTATION DATE September 30, 2026 RESPONSIBLE PERSON Ivan Rentas, President
All outstanding audits have been completed. Audits will be conducted annually and completed within six months following the end of each calendar year to ensure ongoing compliance and timely submissions.
All outstanding audits have been completed. Audits will be conducted annually and completed within six months following the end of each calendar year to ensure ongoing compliance and timely submissions.
2023-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the a...
2023-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the auditor. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.
2023-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at leas...
2023-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Action Taken: The SCCHA discontinued the Loan Program as of November 2019. A complete list of balances owed has been submitted to the Tribal Council with the outstanding balances of those whom had signatory authority forwarded to the St. Croix Tribal Court for further repayment actions.
Finding No.: 2023-020 AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Manage...
Finding No.: 2023-020 AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management processes were promulgated in a SOP on September 18, 2024. The SOPs are under review by an external consultant and recommendations made to improve documentation of time and effort allocable under federal awards. (See also 2023-004, 2023-0009) Corrective Action Plan: I. Establishment of Time and Effort SOPs: PSS will finalize and implement a dedicated Time and Effort Reporting SOP. This policy will explicitly define the key management Level of Effort (LOE) requirements by position and mandate the collection of specific supporting records, including Notice of Personnel Action (NOPA) forms, payroll registers, and certified timesheets. The SOP will feature robust internal controls and supervisory review procedures designed to prevent improper payments and ensure accurate labor distribution. II. Standardization of Key Management Records: PSS will obtain and systematically retain NOPA forms or equivalent documentation for all six positions identified in the grant agreement. This documentation will serve as the primary evidence to demonstrate compliance. III. Labor Distribution Monitoring Controls: PSS is implementing ongoing monitoring controls to ensure continued compliance. This includes a periodic internal review of payroll registers against the original grant agreements to verify that the labor costs charged to the award remain consistent with the approved personnel budget and documented effort. Proposed Completion Date: August 2026 Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org
Finding No.: 2023-017 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Private School Participation Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management disagrees with the finding. PS...
Finding No.: 2023-017 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Private School Participation Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management disagrees with the finding. PSS asserts that timely and meaningful consultations were conducted with private school officials prior to making decisions regarding the size, scope, and funding of equitable services for FY2023. Calculations for the equitable share under the Education Stabilization Funds were performed in accordance with federal regulations, ensuring that per-pupil allocations for eligible private school students and teachers were equitable relative to public school expenditures. PSS maintains that consultation timelines, meeting records, and allocation formulas were maintained. While PSS is continuously refining its administrative workflows, the existing documentation and controls were sufficient to satisfy the requirements of 34 CFR § 299.7. Proposed Completion Date: Resolution in progress and on track for completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org
Finding No.: 2023-016 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Wage Rate Requirement Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings. We a...
Finding No.: 2023-016 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Wage Rate Requirement Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings. We acknowledge that our current procurement and contract administration processes did not consistently incorporate the mandatory Davis-Bacon Act labor standard clauses or the subsequent collection of certified payrolls. PSS is committed to implementing a rigorous compliance framework for all federally funded construction and repair projects. Financial, Procurement, and Grants Management policies procedures were promulgated in a SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Payment procedures are being addressed in a separate SOP. Corrective Action Plan: To ensure full compliance with 29 CFR 5.5 and federal wage rate requirements, PSS will implement the following: I. Standardized Construction Contract Template: PSS Legal Counsel and the Procurement Office will develop a standardized "Federal Construction Contract Addendum." This addendum will contain all mandatory Davis-Bacon Act clauses required by 29 CFR 5.5(a)(1)-(10). Effective immediately, no contract or purchase order exceeding $2,000 for construction, alteration, or repair will be executed without the inclusion of this addendum. II. Mandatory Certified Payroll Submission Protocol: PSS will update its "Notice to Proceed" and project management guidelines to explicitly state that progress payments will be withheld until the contractor submits the required weekly certified payrolls. Contractors will be provided with the Form WH-347 (or an equivalent) to ensure they are using the correct reporting format. III. Pre-Construction Compliance Meetings: For all future Davis-Bacon covered projects, PSS will hold a mandatory pre-construction meeting with contractors to clearly communicate their obligations regarding certified payrolls and the posting of the applicable wage decision at the job site. IV. Document Retention and Review Audit: PSS will implement a "Project Close-out Checklist." Finance will not process the final retention payment for any construction project until the Labor Compliance Monitor certifies that all weekly certified payrolls have been received, reviewed, and filed. V. Updated Standard Operating Procedures and Training: PSS will finalize SOPs and policies internal controls with updated internal controls and procedures for required contract clauses and oversight. Checklists will be updated to include a specific control for Davis-Bacon reporting. Require all current contractors and those identified in this audit to submit certified payrolls for 2023 through the span of their contracts for all Davis-Bacon covered work. PSS Procurement and Supply staff will receive refresher training on cost principles annually regarding required contract clauses and documentation to support compliance with requirements. Proposed Completion Date: September 2026 Name of Contact Person and Title: Contact: Michael Jason A. Babauta, Chief Procurement & Supply Officer Email Address: michael.jason.babauta@cnmipss.org
Finding 2023 – 001: Audit Journal Entries Condition: During audit fieldwork, our testing resulted in significant audit adjustments in order to present materially accurate financial statements. Plan: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparatio...
Finding 2023 – 001: Audit Journal Entries Condition: During audit fieldwork, our testing resulted in significant audit adjustments in order to present materially accurate financial statements. Plan: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork. Anticipated Date of Completion: Fiscal Year 2024 Name of Contact Person: Colleen Lambert, Village Clerk Management Response: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork.
Planned Corrective Action: GSIL will continue to strive to maintain adequate staffing levels within the Finance Department to ensure work is completed timely and to maintain documented separation of duties. A Controller position was added and filled recently to add depth to the department and help w...
Planned Corrective Action: GSIL will continue to strive to maintain adequate staffing levels within the Finance Department to ensure work is completed timely and to maintain documented separation of duties. A Controller position was added and filled recently to add depth to the department and help with these efforts. Additionally, vacant positions have included extensive internal and external recruiting efforts and have also recently been filled. Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Jill Bille, CFO
Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and da...
Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action: Immediately
Action planned in response to finding: 1. Assigned program director and contract specialist to be responsible for the completion of contract terms, with executive oversight. 2. Active USDA portal access always maintained. Name(s) of the contact person(s) responsible for corrective action: Anna Kelle...
Action planned in response to finding: 1. Assigned program director and contract specialist to be responsible for the completion of contract terms, with executive oversight. 2. Active USDA portal access always maintained. Name(s) of the contact person(s) responsible for corrective action: Anna Keller, Finance Manager and Brittany Lucas, Chief Financial Officer Planned completion date for corrective action plan: January 2024
Management Team Ongoing to Fiscal Year 2026 The Authority will conduct annual training on grant management and reporting requirements for all staff involved in the federal programs audit and reporting process. Further, the authority will create checklists of reports required to be submitted to the f...
Management Team Ongoing to Fiscal Year 2026 The Authority will conduct annual training on grant management and reporting requirements for all staff involved in the federal programs audit and reporting process. Further, the authority will create checklists of reports required to be submitted to the federal grantor, to be used to track reporting submission deadlines, including the Federal Audit Clearinghouse (FAC) due date.
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer January 2024 To ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. Eliminating the multi-level review proc...
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer January 2024 To ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. Eliminating the multi-level review process allowed management to meet reporting deadlines more efficiently. Further, the Authority will strengthen financial oversight, by requiring all direct reports (monthly to bi-monthly financial reports) be submitted to the CFO. These reports will be used to continuously monitor program performance, identify any discrepancies, and address issues in a timely manner.
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compli...
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations
Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for r...
Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for record retention. The Authority has also updated its policies and standard operating procedures to ensure greater coverage and effectiveness, and is committed to ongoing improvement and consistently meets all compliance requirements through detailed documentation. These measures have been implemented, training has taken place, and policies have been revised.
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