Corrective Action Plans

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The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
Finding 3754 (2023-002)
Significant Deficiency 2023
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate insta...
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash. An additional step will be added to the process that will require CFO review and approval of calculations of draw-down amounts. Anticipated Completion Date: December 31, 2023
2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulation...
2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Executive Director will review the completed risk assessment to identify specific shortcomings, so that safeguards can be documented in relation to those specific risks. Additionally, he will review the updated GBLA regulations and ensure the University is in compliance. Name of the contact person responsible for corrective action: Brandon Ray, Executive Director, Information Technology Planned completion date for corrective action plan: January 31, 2023.
Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented re...
Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will make the following changes: Awarding: The following are internal controls that the University already has in place to review awards for accuracy. • Financial aid worksheet: As part of the awarding process every award year, a financial aid worksheet is created to verify that the awards input in Colleague are accurate. The worksheet is updated each time there is a change to a student’s financial aid eligibility or status. • COD report monitoring: On a weekly basis, reports are processed to determine if there are any discrepancies between what has been awarded in Colleague and what is being reported/accepted in COD. Any discrepancies found are reviewed and corrected. • Monthly loan/grant reconciliation: The monthly loan/grant reconciliation monitors for any discrepancies between what is shown as disbursed in Colleague and the disbursements that have been accepted by COD. Any discrepancies found are reviewed and corrected. • Over award report: Processed at the beginning of each term, this report details if any students are awarded beyond unmet need and/or cost of attendance. Any discrepancies found are reviewed and corrected. • Enrollment level report: Processed before the start of each term and at the end of the add/drop period, this report evaluates awarded enrollment level against actual enrolled credits. Any discrepancies found are reviewed and corrected. • Disbursement processing rules: There are rules built into the Colleague system to limit disbursement of awards when actual enrollment status does not match awarded status. Any discrepancies found are reviewed and corrected. Beyond the internal controls already in place, the University will implement the following: • Secondary review of awards: For new Financial Aid Counselors, all awards will be reviewed for the first two months to ensure accuracy and commitment to proper training. Additionally, based on current staffing levels, a random selection of 10% of all awarded students will be reviewed to evaluate for awarding accuracy. • Grade level review: After the 10th day of each term, a review will be performed to compare the current class standing of each student to the grade level that was used for awarding. Any discrepancies found will be reviewed and corrected. Return to Title IV (R2T4) Calculations: The Colleague system is used to process R2T4 calculations. This system has been developed to correctly calculate the return formula based on limited information entered by the R2T4 processor. To ensure the correct information is entered, the University will implement a secondary review of all R2T4 calculations. The primary R2T4 processor will enter all required information in the R2T4 calculation screen within Colleague, and then print the screen for review by a secondary member before the return is referred for processing. The primary processor and secondary reviewer will be required to sign off on the printed calculation sheet, verifying the accuracy of the information. The items that will be included as part of the secondary review will be the date of determination, enrollment status, last date of attendance, and institutional charges. Professional Judgment: The University will implement a Professional Judgment Committee. The committee will consist of at least one Financial Aid Counselor and the Director of Financial Aid. The committee will collectively review all the documentation for each case to make a final determination. Name of the contact person responsible for corrective action: Dustin Kummrow, Director of Financial Aid Planned completion date for corrective action plan: November 1, 2023
Finding 3732 (2023-001)
Significant Deficiency 2023
Corrective Action Plan (Prepared by the Charter Holder) Finding 2023 – 001 Management has recognized the need for additional personnel to assist in ensuring compliance and accuracy with various reporting and compliance requirements. In September 2023, the Charter Holder posted a grant manager positi...
Corrective Action Plan (Prepared by the Charter Holder) Finding 2023 – 001 Management has recognized the need for additional personnel to assist in ensuring compliance and accuracy with various reporting and compliance requirements. In September 2023, the Charter Holder posted a grant manager position to support the Chief Financial Officer with state and federal reporting, budgeting, and grant compliance. While the position is vacant, the Charter Holder’s business manager is reviewing financial and compliance reports for accuracy. Management has reached out to Texas Education Agency about the reporting error and is waiting for further instructions on how to correct the reporting error. Responsible Party: Marian Hamlett, CFO Implementation Date: Immediately
2023-002 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Explanation of disagreement with audit fin...
2023-002 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024
2023-001 Lack of Segregation of Duties Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overa...
2023-001 Lack of Segregation of Duties Criteria: Internal controls should be in place that provide adequate segregation of duties and reduce overlapping accounting functions, especially in cash receipts and disbursements. In addition, those functions should be segregated from those overseeing overall finances. Condition: The responsibility for the District's bookkeeping and accounting functions is assumed by a limited number of individuals. The Business Manager enters and approves journal entries and reconciles all bank accounts. Cause: The District has determined that hiring additional staff to perform separate accounting duties would be too costly and not an effective use of resources. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: The District should be aware of the need for separation of duties and provide for as much separation of duties as feasible in the circumstances. Response: Management of the District is aware that the current number of accounting staff does not allow for full segregation of duties. Segregation of duties is enhanced whenever possible and the Board of Education and management assumes an active roll through monthly review of receipts and disbursements and monthly financial reports. The Superintendent and Business Manager are in constant communication regarding the District's finances. The Superintendent is not involved in processing day to day financial transactions. Contact Person: Doreen Treuden Anticipated Completion: Not Applicable
Plan: Pre-made certification packets will be utilized when meeting with tenants to ensure all required documents and back up documentation are accounted for. A second staff member will review new and annual certifications to ensure all required documents from the pre-made packet are accounted for. ...
Plan: Pre-made certification packets will be utilized when meeting with tenants to ensure all required documents and back up documentation are accounted for. A second staff member will review new and annual certifications to ensure all required documents from the pre-made packet are accounted for. Contact: Christina Morin, Program Director. Anticipated Completion date: September 28, 2023
Plan: A second staff member will review certifications and annual certifications to ensure accuracy based on the required back up documentation. Contact: Christina Morin, Program Director. Anticipated completion date: September 28, 2023.
Plan: A second staff member will review certifications and annual certifications to ensure accuracy based on the required back up documentation. Contact: Christina Morin, Program Director. Anticipated completion date: September 28, 2023.
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2023-002 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the ...
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2023-002 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The District should segregate duties where possible and create checks and balances. The Board should be aware of this problem and closely review and approve all financial related information. Action Taken: The District concurs with the recommendation. The District is reviewing its financial policies and procedures to better segregate duties where possible. The Superintendent will make the Board aware of their responsibility in regards to reviewing and approving financial items and asking questions. Anticipated Date of Completion: Ongoing
Views of Responsible Officials and Planned Corrective Actions: The Association will undertake review of its procedures related to FFATA reporting and will implement additional controls to ensure timely submission of FFATA sub-award reports.
Views of Responsible Officials and Planned Corrective Actions: The Association will undertake review of its procedures related to FFATA reporting and will implement additional controls to ensure timely submission of FFATA sub-award reports.
Finding #2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – First Quarter of 2024 Information on the Major Federal Program: U.S. Department of Health and Human Services Name...
Finding #2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – First Quarter of 2024 Information on the Major Federal Program: U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Corrective Action Plan: Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.
Corrective Action Plan (CAP) The Ozark Housing Authority (Housing Authority) To the Department of Housing and Urban Development, During the Fiscal Year 2023 audit, the Housing Authority could not locate two tenant files along with one HUD 50058 Reexamination form, two HUD 9886 Authorization forms ...
Corrective Action Plan (CAP) The Ozark Housing Authority (Housing Authority) To the Department of Housing and Urban Development, During the Fiscal Year 2023 audit, the Housing Authority could not locate two tenant files along with one HUD 50058 Reexamination form, two HUD 9886 Authorization forms and three third party verification documents. The Housing Authority’s Executive Director, Dannie Walker, is responsible for implementing the corrective action plan. CAP developed to resolve audit finding: Finding 2023-001 – Tenant Eligibility and Reexaminations We were aware of the tenant file deficiencies before audit fieldwork began and had begun implementing the recommendation of strengthening internal controls over eligibility requirements in addition to having made personnel changes to the eligibility department. The deficiency that led to this finding will be corrected by March 31, 2024.
Finding 3670 (2023-001)
Significant Deficiency 2023
The District will implement controls in its meal claim process to ensure that student meals claimed for reimbursement equal student meals served. The Food Service Supervisor and/or Food Service Administrative Assistant will create a summary meal count sheet each month totaling the number of student ...
The District will implement controls in its meal claim process to ensure that student meals claimed for reimbursement equal student meals served. The Food Service Supervisor and/or Food Service Administrative Assistant will create a summary meal count sheet each month totaling the number of student meals seved based on the electronic and manual meal count sheets prior to submitting the meal claim in the Michigan Nutrition Data System (MiND). The monthly meal claim submitted will be filed with the supporting documentation an dsigned by the individual submitting the claim attesting that the meals claimed match the meals counted.
View Audit 5732 Questioned Costs: $1
#2023-004 Material Weakness related internal controls and compliance with Special Tests and Provisions – Verifications: The District did not perform verification of free/reduced meal applications until March 2023. Recommendation: Auditor recommends the District maintain close communication wit...
#2023-004 Material Weakness related internal controls and compliance with Special Tests and Provisions – Verifications: The District did not perform verification of free/reduced meal applications until March 2023. Recommendation: Auditor recommends the District maintain close communication with the Department of Education, particularly during any period when there is a change in manner in which the food service program operates. Action Taken: The Bandon School District will maintain close communication with the Department of Education, particularly during any period when there is a change in the manner in which the food service program operates. The Director of Food Services will also reach out to the verification team to make sure verifications are done promptly. They will also check regularly for incoming applications that also must be verified promptly. Effective May 2023.
#2023-003 Significant Deficiency in internal controls and noncompliance related to reporting: The District did not have adequate internal controls over meal claiming process and as a result, errors were made and not detected. Recommendation: Personnel need to be assigned to provide a second rev...
#2023-003 Significant Deficiency in internal controls and noncompliance related to reporting: The District did not have adequate internal controls over meal claiming process and as a result, errors were made and not detected. Recommendation: Personnel need to be assigned to provide a second review of the meal counts. Ideally, software would be used to avoid human error in tallying. Action Taken: Since May of 2023, the Bandon School District has used Mealtime to avoid human error in tallying. The Food Services Director reviews these numbers monthly to ensure accuracy.
#2023-002 Material Weakness related to eligibility for free and reduced price meals: During a transitional year where all meals were being provided free to all students under various funding sources, the District did not actively solicit applications from households and did not process those appli...
#2023-002 Material Weakness related to eligibility for free and reduced price meals: During a transitional year where all meals were being provided free to all students under various funding sources, the District did not actively solicit applications from households and did not process those applications that were received until nearly six months later. Recommendation: Auditor recommends the District maintain close communication with the Department of Education, particularly during any period when there is a change in manner in which the food service program operates. Action Taken: The Bandon School District will maintain in close communication with the Department of Education, particularly during any period when there is a change in the manner in which the food service program operates. Director of Food Services will also regularly reach out to ODE’s assigned Nutrition Specialist to verify the certification of students’ classification on free, reduced and paid students is correct. Effective May of 2023.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative.
We will continue to review our procedures and implement additional controls where possible.
We will continue to review our procedures and implement additional controls where possible.
Finding 3580 (2023-001)
Significant Deficiency 2023
Department of Education Bucknell University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consisten...
Department of Education Bucknell University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Bucknell is currently reviewing its existing process of reporting student enrollment data to the NSLDS. The University through its Registrar and Financial Aid Office will update current procedures to include a more thorough verification of third-party servicer submissions to the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Tim Kracker, University Registrar and Erin Wolfe, Director, Financial Aid Planned completion date for corrective action plan: December 2023 If the Department of Education has questions regarding this plan, please call Elizabeth D. Stewart, Associate Vice President, Treasurer & Controller at 570-577-3108.
THE SCHOOL DISTRICT DOES AGREE WITH THE FINDING. HOWEVER, BEING A DISTRICT OF THIS SIZE, IT IS NOT PRACTICAL TO HIRE ADDITIONAL STAFF TO SEGREGATE DUTIES. THE BOOKKEEPER DOES NOT HANDLE CASH. DEPOSITS ARE MADE BY THE SECRETARIES/PRINCIPALS OR ORGANIZATIONAL SPONSOR. THE SUPERINTENDENT REVIEWS AN...
THE SCHOOL DISTRICT DOES AGREE WITH THE FINDING. HOWEVER, BEING A DISTRICT OF THIS SIZE, IT IS NOT PRACTICAL TO HIRE ADDITIONAL STAFF TO SEGREGATE DUTIES. THE BOOKKEEPER DOES NOT HANDLE CASH. DEPOSITS ARE MADE BY THE SECRETARIES/PRINCIPALS OR ORGANIZATIONAL SPONSOR. THE SUPERINTENDENT REVIEWS AND AUTHORIZES ALL MONETARY MATTERS. HE ALSO CONTINUALLY EXAMINES FINANCIAL STATEMENTS. THE BOARD OF EDUCATION ALSO APPROVES ALL BILLS PAYABLE AND FUND BALANCES MONTHLY. THE SCHOOL DISTRICT WILL CONTINUE TO MITIGATE THE SEGREGATION OF DUTIES FINDING.
District Response: Corrective Action Plan: Fiscal Audit Finding 2023-004 Objective: To address the material weakness in internal control over federal awards related to the accuracy and completeness of the Schedule of Expenditures of Federal Awards (SEFA) and to prevent future discrepancies. Respo...
District Response: Corrective Action Plan: Fiscal Audit Finding 2023-004 Objective: To address the material weakness in internal control over federal awards related to the accuracy and completeness of the Schedule of Expenditures of Federal Awards (SEFA) and to prevent future discrepancies. Responsible Officials: ● Director of Business and Finance ● Grant Accounting Manager ● Internal Audit Team Timeline: The corrective action plan will be implemented immediately and completed within the next six months upon partnering with Yeo & Yeo or Plante Moran. 1. Immediate Steps: 1.1 Notification and Acknowledgment: ● Notify the relevant personnel, including the Director of Business and Finance and Grant Accounting Manager, about the audit finding. ● Acknowledge the importance of addressing the material weakness and its potential impact on SEFA accuracy. 1.2 Internal Review: ● Conduct an internal review of the SEFA, focusing on the accuracy of the federal awards reported. ● Identify any additional discrepancies or omissions in the SEFA. 1.3 Communication Plan: ● Develop a communication plan to inform key stakeholders (grantors, auditors, etc.) about the identified issue, the corrective action plan, and the steps being taken to address the material weakness. 2. Short-Term Corrective Actions (Within 3 Months): 2.1 Template Creation: ● Develop a standardized template to reconcile federal grant activity with the general ledger revenue, expenditure, and deferral balances. ● Ensure that the template includes provisions for capturing indirect costs, receivables, and deferrals for all federal awards. 2.2 Training: ● Provide training to relevant staff members, especially those involved in grant accounting, on the new reconciliation template and the importance of timely and accurate reporting. 2.3 Review and Update Processes: ● Review and update the monthly close process to ensure that reconciliations are completed in a timely manner. ● Establish clear procedures for handovers in case of personnel turnover. 3. Mid-Term Corrective Actions (Within 6 Months): 3.1 Implementation of Template: ● Implement the newly created reconciliation template for all federal awards. ● Ensure that the template is consistently used for all relevant financial reporting. 3.2 Monitoring and Oversight: ● Establish a system for ongoing monitoring and oversight of the reconciliation process. ● Conduct periodic reviews to ensure compliance with the new procedures. 3.3 Internal Controls Enhancement: ● Enhance internal controls related to federal awards by implementing additional checks and balances. ● Document these controls and communicate them to relevant personnel. 4. Long-Term Preventive Measures: 4.1 Succession Planning: ● Develop and implement a succession plan for critical financial positions, including the Director of Business and Finance. ● Ensure that key responsibilities are clearly defined and documented. 4.2 Continuous Improvement: ● Foster a culture of continuous improvement within the financial management team. ● Encourage regular feedback and evaluations to identify areas for improvement in processes and controls. 5. Monitoring and Reporting: 5.1 Progress Reports: ● Provide regular progress reports to senior management and the audit committee on the status of corrective actions. ● Highlight any challenges encountered and the steps taken to address them. 5.2 Follow-up Audits: ● Schedule follow-up audits to assess the effectiveness of the corrective actions taken. ● Use the results to make further improvements to internal controls and processes.
2023-002 Finding: Assessment System Security Title 1, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))) Summary of Finding: The District is required to establish internal controls to ensure assessment security. Historically one of these internal controls included a Site Visit Sche...
2023-002 Finding: Assessment System Security Title 1, Section 1111(b)(2)(B)(iii) of the ESEA (20 USC 6311(b)(2)(B)(iii))) Summary of Finding: The District is required to establish internal controls to ensure assessment security. Historically one of these internal controls included a Site Visit Schedule to provide security assessment reviews. Site visits were performed at a select number of schools but did not include all Title schools in compliance with the requirements of the grant. Status: Corrective action in progress Client Planned Action: The District concurs with the recommendations and is currently implementing a process to ensure compliance. The Chief of Strategy and Data Acquisition has developed in coordination with the district Director of Metrics and Accountability, Area Superintendents, and the Colorado Department of Education Assessment Division a process processes to implement the needed internal controls that will ensure compliance to this requirement. They are as follows: Area Data Coaches will visit their portfolio of schools in the first 3 days of the state assessment window to ensure compliance with assessment security policies and procedures. Each data coach will receive full training from the CDE and the District Assessment Coordinator to ensure compliance with all security protocols in each building. Education Insights utilizes Area Data Coaches who work in close partnership with each Area Superintendent. Client Responsible Party: Natasha Crouse, Director of Metrics and Accountability. Each site visit will be documented with findings and any pertinent outcomes recorded. These logs will be securely stored on the Education Insights shared drive. Client Responsible Party: Dr. David Khaliqi, Chief of Strategy and Data Acquisition Completion Date: Assessment security training implemented as of March. 1, 2024. Standardized security assessment checklists and rubrics will be established by April 1, 2024. All site visits will be completed by April 10, 2024. Ongoing training throughout the year will be accomplished as needed. Adjustments and revisions to initial processes will be implemented as needed. Time and Effort certifications will be completed semi-annually.
Finding 3466 (2023-003)
Significant Deficiency 2023
We concur with the auditor’s finding. We will be completing a full audit of remaining Perkins files to ensure that all necessary documentation is accounted for and properly filed. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Correcti...
We concur with the auditor’s finding. We will be completing a full audit of remaining Perkins files to ensure that all necessary documentation is accounted for and properly filed. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was started in October and will be completed by December.
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