Corrective Action Plans

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Finding 2025-001 Non – Adherence to Davis Bacon Act Criteria and Condition: The Authority did not appoint a Labor Compliance Officer, as is required to ensure the Davis Bacon Act is being followed. Recommendation: The auditors recommended that the Authority appoint a Labor Compliance Officer. Manage...
Finding 2025-001 Non – Adherence to Davis Bacon Act Criteria and Condition: The Authority did not appoint a Labor Compliance Officer, as is required to ensure the Davis Bacon Act is being followed. Recommendation: The auditors recommended that the Authority appoint a Labor Compliance Officer. Management Response: The Authority amended their contract with the consulting engineer and established the engineer as the Labor Compliance Officer. Name and Title of Contact Person Responsible for Corrective Action: Mark Catranis, Controller
View Audit 372028 Questioned Costs: $1
Finding 2025-004: Student Financial Aid – Enrollment Reporting Finding: For four out of forty (10%) student enrollment reporting selections, the student's status change at the campus level and program was not properly reported to NSLDS with the required timeframe. Cause: The student's status change ...
Finding 2025-004: Student Financial Aid – Enrollment Reporting Finding: For four out of forty (10%) student enrollment reporting selections, the student's status change at the campus level and program was not properly reported to NSLDS with the required timeframe. Cause: The student's status change was after the last scheduled reporting transmission file of the semester, therefore their status change was not captured in the NSLDS reporting submission. Corrective Actions Taken or Planned: During the Summer of 2024, the Registrar’s Office was undergoing a period of transition. The newly appointed Registrar, Mai Aly, had just started in her role, and the Associate Registrar was out on medical leave. This staffing disruption contributed to delays in identifying and processing student status changes, which in turn impacted the timeliness of NSLDS reporting. To address this issue and strengthen compliance with NSLDS reporting requirements, the College has implemented the following measures: 1. Operations Calendar: The Registrar’s Office has developed and implemented a comprehensive Operations Calendar. As part of this calendar, withdrawal reporting tasks have been scheduled at the beginning of June, July, and August to ensure timely identification and submission of summer enrollment changes. 2. Designated Responsibility: The Associate Registrar has been assigned as the primary staff member responsible for reporting summer withdrawals to the National Student Clearinghouse (NSC), ensuring continuity and accountability in the reporting process. 3. Staff Training and Documentation: Relevant staff have been retrained on NSC/NSLDS reporting requirements to reinforce procedures for monitoring and reporting enrollment changes during the summer months to prevent future summer enrollment reporting issues. Contact Person Responsible: Jennifer Kenworth, Associate Registrar Lake Forest College Completion Date: 11/1/2025
Finding 2025-003: Student Financial Aid – Excess Cash Finding: Lake Forest College had excess cash for the FDL program ranging from $24,903 to $3,683,698 during the period of January 30, 2025 through February 7, 2025. In this situation, the excess cash exceeded one percent of total prior year drawdo...
Finding 2025-003: Student Financial Aid – Excess Cash Finding: Lake Forest College had excess cash for the FDL program ranging from $24,903 to $3,683,698 during the period of January 30, 2025 through February 7, 2025. In this situation, the excess cash exceeded one percent of total prior year drawdowns, and the amount was not returned within a seven-day period. Cause: The College drew down funds in advance of the Spring semester which is allowed based on the College’s cash management method. However, due to timing differences, the funds were not ultimately disbursed to students until 8 days after the drawdown was made. Corrective Actions Taken or Planned: On January 27, 2025, the Office of Management and Budget issued a directive pausing the disbursement of federal grants and loans, effective the following day. With uncertainty surrounding whether this pause applied to the FDL program, its duration, and the potential impact on the College’s cash flow, the Business Office made a one-time exception to its longstanding best-practice process. Instead of using finalized disbursement data, the College opted to draw funds based on preliminary disbursement information to mitigate potential financial disruption. To prevent recurrence and ensure compliance with federal cash management regulations, the College has implemented the following corrective measures: 1. Return to Standard Practice: The Business Office has resumed its standard drawdown procedure, which utilizes finalized disbursement data after the College’s add/drop date to ensure alignment with actual student disbursements. 2. Contingency Protocol for Exceptional Circumstances: In the event of future extraordinary circumstances, the Business Office will implement a conservative drawdown buffer, limiting initial draws to no more than 66% of preliminary disbursement estimates. This approach will reduce the risk of excess cash while maintaining operational flexibility. 3. Enhanced Coordination and Communication: The Business Office will maintain close coordination with the Office of Financial Aid, along with federal agencies and monitor guidance during periods of uncertainty to ensure timely and compliant decision-making. Contact Person Responsible: AJ Rodino, AVP for Business Lake Forest College Completion Date: 11/1/2025
View Audit 371906 Questioned Costs: $1
Finding 2025-002: Suspension and Debarment Finding: For two out of two vendors (100%) tested, the College did not provide sufficient documentation that a suspension and debarment check was performed prior to entering into a contract with the vendor. Cause: The College did not have controls in place ...
Finding 2025-002: Suspension and Debarment Finding: For two out of two vendors (100%) tested, the College did not provide sufficient documentation that a suspension and debarment check was performed prior to entering into a contract with the vendor. Cause: The College did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. Corrective Actions Taken or Planned: As part of the procurement process review, a more robust policy will be developed related to vendor management. The policy will include specific definitions and limits for the types of transactions (non-procurement, procurement contracts, “covered transactions”). By October 31, 2025, the Business Office will communicate with all current PI’s an interim policy including the need for competitive bids, vendor screening, and more detailed descriptions. Contact Person Responsible: Doug MacKay, Controller Lake Forest College Completion Date: January 31, 2026
Student Financial Assistance Cluster – CFDA No. 84.038 Recommendation: We recommend that the College review all retired/assigned Perkins loan files to ensure MPNs are present and properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...
Student Financial Assistance Cluster – CFDA No. 84.038 Recommendation: We recommend that the College review all retired/assigned Perkins loan files to ensure MPNs are present and properly retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review assigned and retired files for the Master Promissory Notes. Name of the contact person responsible for corrective action: Deb Schmidt, Director of Student Accounts Planned completion date for corrective action plan: February 28, 2026
Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the au...
Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will maintain documentation of monthly communication between the External Programs Manager, the Financial Aid Director and the Director of Accounting, related to the monthly reconciliation of Federal Direct Loans, Federal Pell Grant. Federal SEOG and Federal Work Study programs. Name of the contact person responsible for corrective action: Jenae Schmidt, Director of Financial Aid Planned completion date for corrective action plan: September 30, 2025
Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been as...
Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been assigned refresher training on federal loan awarding requirements, with specific emphasis on annual and aggregate loan limits and the prioritization of subsidized eligibility. 3. System-level reports have been created to identify potential discrepancies in loan allocation, which will be reviewed monthly by the Financial Aid Office. Ongoing Monitoring: The Director of Financial Aid will oversee the monitoring process each term to ensure compliance with 34 CFR 685.203, and 34 CFR 685.301 requirements. Any discrepancies identified will be corrected immediately and documented as part of the institution’s internal compliance log. North Greenville University believes these corrective measures address the issue identified and will prevent recurrence of similar errors. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2025
Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential ...
Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential over-awards. • Conduct random reviews of aid packages to ensure compliance. • Document system changes and over-award resolution. Person Responsible for Corrective Action Plan: Mike Sapienza, Senior VP for Enrollment Services Anticipated Date of Completion: May 31, 2026
View Audit 370986 Questioned Costs: $1
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines da...
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.
View Audit 370942 Questioned Costs: $1
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Con...
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entere...
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entered into a purchase and sale agreement with The Christ Hospital to acquire the property for $1,485,528. Pending HUD approval. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar
View Audit 370591 Questioned Costs: $1
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entere...
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entered into a purchase and sale agreement with The Christ Hospital to acquire the property for $1,485,528. Pending HUD approval. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar
View Audit 370591 Questioned Costs: $1
FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within ...
FINDING: 2025-005 Name of contact person: Lynn Gierke, Township Supervisor, 906-523-4000 Description of Finding: In accordance with 2 CFR Section 200.319(d), non-federal entities must have their own written policies for procurement transactions. The policy should incorporate all requirements within 2 CFR section 200.318 through 200.326 of the Uniform Guidance. Corrective Action Plan: We will create a procurement policy that meets all the requirements of 2 CFR section 200.318 through 200. Proposed Completion Date: March 31, 2026
Finding 2025-003 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Procurement Questioned Costs: None Name of contact person and title: Pat Bishop, President Condi...
Finding 2025-003 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Procurement Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The entity has not established or documented a formal procurement policy or procedures to guide the acquisition of goods and services. No written guidelines were provided during the review period. Management Response: Management intends to establish a procurement policy. Status: In progress Anticipated Completion Date: Estimated 2025
Finding 2025-002 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Special Tests and Provisions Questioned Costs: None Name of contact person and title: Pat Bishop...
Finding 2025-002 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Special Tests and Provisions Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The management did not establish did not establish or maintain required tax and insurance reserve accounts during the fiscal year. These reserves are required under loan and regulatory agreements to ensure funds are available to meet property tax and insurance obligations when due. Management Response: The project will establish reserve accounts for taxes and insurance. Status: In progress Anticipated Completion Date: Estimated 2025
Finding 2025-001 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Activities allowed or unallowed, allowable costs/ cash management, eligibility, equipment, perio...
Finding 2025-001 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Activities allowed or unallowed, allowable costs/ cash management, eligibility, equipment, period of performance, procurement, program income, reporting, special tests Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The auditee did not submit the required audit reports to the Federal Audit Clearinghouse (FAC) and Rural Development (RD) in a timely manner. Specifically:  The 2023 Audit Report was not submitted to the FAC as required under 2 CFR Part 200, Subpart F.  The 2024 Audit Report was submitted past the regulatory deadline to both the FAC and RD. Management Response: Management plans to develop and implement an internal audit compliance calendar with clearly defined submission deadlines for all audit-related deliverables, including due dates for the FAC and RD and Create an internal checklist and sign-off process to confirm that each audit deliverable has been submitted to all required agencies and portals. Status: In progress Anticipated Completion Date: Estimated 2025
Finding Number: 2025-005 Condition: The Township did not have the appropriate controls in place to ensure reports and reimbursement requests that were required to be submitted under the grant were complete and accurate as well as ensuring the matching requirement was properly reviewed. Planned Corre...
Finding Number: 2025-005 Condition: The Township did not have the appropriate controls in place to ensure reports and reimbursement requests that were required to be submitted under the grant were complete and accurate as well as ensuring the matching requirement was properly reviewed. Planned Corrective Action: The Township will update the Grant Policy to include a requirement for dual review on all grant reporting. Contact person responsible for corrective action: Finance Director Anticipated Completion Date: 3/31/2026
Finding 2025-002 See response to finding 2025-001.
Finding 2025-002 See response to finding 2025-001.
View Audit 367580 Questioned Costs: $1
2025-002. HUD Project loan made to other HUD Programs Corrective action planned: Trinidad Housing Authority is searching for other Accounting Services for the Housing Authority. We are currently working on a payment plan with payroll for Corazon Square and have started processing payments to Low Ren...
2025-002. HUD Project loan made to other HUD Programs Corrective action planned: Trinidad Housing Authority is searching for other Accounting Services for the Housing Authority. We are currently working on a payment plan with payroll for Corazon Square and have started processing payments to Low Rent. As we are moving forward in our search for accounting services, we will continue to pay equal amounts monthly to Low Rent. Contact person: Kathee Gutierrez Adams, Interim Executive Director. Anticipated completion date: Our goal is to be completely in compliance by end of fiscal year March 31, 2026.
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported wit...
FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support the timeliness of federal compliance. Response: There is no disagreement with this audit finding. Action taken in response to finding: Some of the corrective actions noted in our response to finding 2025-001 also apply here. For example, quality assurance reports to identify students who withdraw from all classes in a part of term and the upcoming joint training and process mapping session with Student Financial Services and the Registrar’s Office will strengthen understanding of how enrollment status updates drive downstream compliance, including R2T4 processing. These steps will also ensure exceptions are addressed consistently and that communication channels between offices are clear. To address immediate gaps specific to R2T4 compliance, the Registrar’s Office has enhanced training regarding R2T4 compliance requirements related to recording withdrawals and enrollment changes in a timely, accurate and consistent manner. Additional quality checks are being implemented to confirm that withdrawal dates and status changes are entered accurately into the student information system so that R2T4 calculations are completed within federal timeframes. Together, these interventions are designed to ensure the timeliness and accuracy of R2T4 processing and compliance with federal requirements. We expect to have these corrective actions completed by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research
FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status an...
FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis. Response: There is no disagreement with this audit finding. Action taken in response to finding: Gonzaga has already taken action and implemented quality assurance reports and monitoring to ensure all student changes (enrollment status and address changes) are reported timely. Additionally, to strengthen compliance going forward, Student Financial Services and the Registrar’s Office are partnering to conduct a joint annual training and process mapping session for key personnel. This session will provide an overview of enrollment reporting requirements, outline the steps needed when exceptions to normal policies occur, and evaluate processes to improve understanding of how decisions affect both upstream and downstream functions. The session will also focus on building a shared understanding of reporting processes, identifying gaps in procedures and knowledge, and establishing communication channels so that exceptions are addressed timely, consistently and appropriately. These actions are designed to enhance internal controls and ensure compliance of timely reporting between the system of record and the reporting system, and we expect to complete this training by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research
2025-004 Cash Management (repeat of finding 2024-008) Corrective action planned: Beginning April 1, 2025, when the organization was made aware of this finding in last year’s audit, OMC took immediate corrective action. The CFO/Designee monitors expenses and prepares a detailed report of expenditures...
2025-004 Cash Management (repeat of finding 2024-008) Corrective action planned: Beginning April 1, 2025, when the organization was made aware of this finding in last year’s audit, OMC took immediate corrective action. The CFO/Designee monitors expenses and prepares a detailed report of expenditures claimed for reimbursement and retains this documentation along with supporting invoices. A qualified, knowledgeable CFO will continue to ensure compliance with these requirements. Anticipated completion date: Corrective Action taken on April 1, 2025. Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations
Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Internal control procedures will be developed and implemented by September 2025.
Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Internal control procedures will be developed and implemented by September 2025.
The Agency acknowledges this error and agrees with the recommendations. The Agency provides the additional context that it has been determined that where incorrect drawdowns were made - they were underdrawn, not overdrawn. No drawdowns were determined to include anything beyond known, justifiable, a...
The Agency acknowledges this error and agrees with the recommendations. The Agency provides the additional context that it has been determined that where incorrect drawdowns were made - they were underdrawn, not overdrawn. No drawdowns were determined to include anything beyond known, justifiable, and allowable expenses. Previous T &TA support from the Office of Head Start and monitoring reviews from other fiscal agencies had not previously revealed this concern and recommendations were made to carry out drawdowns in this manner. The Finance department is actively working with the new recommendation from the auditors to use the accounting system (MIP) and to implement a new payroll and reconciliation procedure which will prevent future errors.
Finding 576088 (2025-003)
Significant Deficiency 2025
Finding 2025-003: Account Reconciliation Procedures Type of Finding: Control U.S Department of Housing and Urban Development Direct program Assistance Listing Number: 14.251 Award Numbers: B-24-CP-MI-1149 Award Year End: August 31, 2032 Recommendation: The Township should establish proced...
Finding 2025-003: Account Reconciliation Procedures Type of Finding: Control U.S Department of Housing and Urban Development Direct program Assistance Listing Number: 14.251 Award Numbers: B-24-CP-MI-1149 Award Year End: August 31, 2032 Recommendation: The Township should establish procedures to verify that expenditures are properly tracked by individual grant to ensure that individual disbursements are not allocated to more than one grant. Action Taken: The Township will create a spreadsheet to track expenditures by individual grants that will be updated as individual disbursements and receipts occur. Responsible Person and Anticipated Completion Date: Township Treasurer, March 31, 2026. If the Michigan Strategic Fund has questions regarding this plan, please call Rebecca Griffin at 231-861-5853.
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