Corrective Action Plans

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Finding 34786 (2022-003)
Significant Deficiency 2022
We already implemented a formal review and approval process in 2023 and anticipate this finding to be resolved on our next year audit. We will also ensure the review and approval is properly documented.
We already implemented a formal review and approval process in 2023 and anticipate this finding to be resolved on our next year audit. We will also ensure the review and approval is properly documented.
FINDING 2022-003? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.063 ($684,817) 84.007 ($34,837) Award Number: P268K223315 P063P213315 P...
FINDING 2022-003? R2T4 Calculation Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($1,119,033) 84.063 ($684,817) 84.007 ($34,837) Award Number: P268K223315 P063P213315 P007A213421 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $26.85 (84.268) $97.40 (84.007) Condition Found: The Title IV funds were not returned timely for two of the forty students in the compliance testing sample. In addition, the R2T4 was not calculated correctly for two of the three students noted above. The incorrect number of days in the semester was used for both students. The remaining R2T4s calculated by the University were reviewed. Two additional R2T4s were not completed timely and one of the additional R2T4s was not calculated correctly. Federal Pell Grant funds returned for not beginning a module course were not excluded from the R2T4 calculation. Corrective Action Plan: Management agrees with this finding. ? For the first student in question, the R2T4 was completed timely, but the incorrect number of days was used in the R2T4 calculation. $26.85 of Federal Direct Loans were returned to the Department of Education in December 2022. ? For the second student in question, the R2T4 was completed and accepted late by the third-party servicer. In addition, the incorrect number of days was used in the R2T4 calculation. An additional $65.59 of Federal Pell Grant funds were disbursed to the student in December 2022. ? For the third student in question, the R2T4 was not completed timely and accepted late by the third-party servicer. The R2T4 was not completed until April 2022 which was more than forty-five days after the date of determination. ? For the fourth student in question, the incorrect Federal Pell Grant disbursed figure was used in the calculation. An additional $97.40 of FSEOG funds were returned in December 2022. In addition, the R2T4 was not calculated within 45 days of the date of determination, so the original funds were returned late. ? For the fifth student in question, the R2T4 was not reviewed and approved by the TPA within 45 days of the date of determination. The correct post-withdrawal disbursement was made in August 2022. Anticipated Completion Date: The corrective action was completed in November 2022. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037
FINDING 2022-001 ? Financial Close and Reporting Condition Found: During our audit, we noted the following: ? The University did not record the expenses related to the Paycheck Protection Program loan or HEERF funds correctly. Instead of recognizing qualified expenses as revenue, the University ...
FINDING 2022-001 ? Financial Close and Reporting Condition Found: During our audit, we noted the following: ? The University did not record the expenses related to the Paycheck Protection Program loan or HEERF funds correctly. Instead of recognizing qualified expenses as revenue, the University reduced the related expense accounts. ? Discounts for El Camino online students were not recorded correctly. Corrective Action Plan: Management agrees with the auditors? finding. Randall University, beginning in the Fall of 2021 began using an outside accounting firm to assist our business office, finance staff, and financial aid staff with financial reporting and accounting. The contract accounting firm was used in 2021-2022 to address many financial reporting and accounting processes. In response to this finding, Randall University will have an independent review of non-standard journal entries added to the contract accountant?s scope-of-work as a part of Randall University?s financial closing and reporting processes. The contract accountant will communicate with the auditing firm to seek guidance and requirements to better address this issue. Anticipated Completion Date: The corrective action is in process and will completed by June 2023. Contact Person: Todd Jenson, CFO 405-912-9475
See Corrective Action Plan for chart/table
See Corrective Action Plan for chart/table
Finding 34755 (2022-003)
Significant Deficiency 2022
Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the...
Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the covered transaction with entity (2 CFR section 180.300) Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: Staff Training ? November 2023
Miles City Eagle Manor Corrective Action Plan June 30, 2022 2022-001 Delinquent Debt Payments Underpayment of the flex subsidy loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the paym...
Miles City Eagle Manor Corrective Action Plan June 30, 2022 2022-001 Delinquent Debt Payments Underpayment of the flex subsidy loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these suggestions as of the date on this report, November 3, 2022. Karen Burkett, the Managing Agent, will work with the Organization to resolve this matter. The anticipated completion date is June 30, 2023.
Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...
Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The entity has addressed this in the current year by providing additional training and expectations set forth to the subrecipient (WRI). Additionally, the Board has worked with DWD to ensure the requirement will be met in the current year. Name of the contact person responsible for corrective action: Jon Menz Planned completion date for corrective action plan: June 30, 2023 If involved agencies have any questions regarding this plan, please call Jon Menz at 715-235-8393
3) Finding 2022-003 ? Student Financial Assistance ? Enrollment Reporting Management?s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The...
3) Finding 2022-003 ? Student Financial Assistance ? Enrollment Reporting Management?s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its controls and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Mattavia Ward, Director of Admissions Implementation Date: Immediately
2022-001 Return to Title IV Recommendation: We recommend that the College review and implement procedures to ensure that withdrawals are properly communicated to all departments and processed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Act...
2022-001 Return to Title IV Recommendation: We recommend that the College review and implement procedures to ensure that withdrawals are properly communicated to all departments and processed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: So that we do not have to rely upon other offices to notify the Financial Aid Office of students not returning, the College has developed a report to detect this condition. We ran the report and no additional students were found to be in this condition. At a minimum, this report will be run on a monthly basis. Name(s) of the contact person(s) responsible for corrective action: William Healy Planned completion date for corrective action plan: July 2022
2022-003 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of a total tenant population of approximately 145 tenant files, 15 files were selected for testing. Exceptions wer...
2022-003 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of a total tenant population of approximately 145 tenant files, 15 files were selected for testing. Exceptions were noted as follows: ? 1 tenant file where the Authority was unable to locate certain documents and therefore could not test items such as Form 9886, birth certificates, social security cards, income and deduction support, utility allowance schedules and EIV verification. ? 1 tenant file where dependent?s 214 affidavit was not signed. However, we did note that the dependent was a US Citizen (per review of birth certificate) and therefore eligible for the program. ? 1 tenant file where tenant?s reported income was incorrect on the Form 50058. However, this had no impact on tenant?s rent as this was a flat rent unit. We also noted as part of our new admissions testing (3 selected for testing out of population of 23 new admissions) the following: ? 1 new admission where the applicant and dependent?s Form 214 were not signed. However, it was noted that the applicants were citizens (per review of birth certificate information) and therefore eligible for the program. Auditor?s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were not able to locate certain documents. We will assure that files are complete and are supported with proper documentation.
Ecology Education, Inc. Corrective Action Plan For the Year Ended December 31, 2022 Finding 2022-001 Condition The School has not prepared written policies which could result in potential noncompliance. Corrective Action Taken or Planned Management is currently reviewing the 2022 compliance ...
Ecology Education, Inc. Corrective Action Plan For the Year Ended December 31, 2022 Finding 2022-001 Condition The School has not prepared written policies which could result in potential noncompliance. Corrective Action Taken or Planned Management is currently reviewing the 2022 compliance supplement (2 CFR PART 200, APPENDIX XI) which applies to most federal awards including USDA RD financing. Management understands this supplement is issued annually and can be obtained online. Specific review includes the matrix for federal programs on page 21, and details for ALN 10.766 (USDA Community facilities loans) which begins on page 275. Management has prioritized preparing written policies in direct alignment of the 2022 compliance supplement related to internal control and compliance with federal award requirements. The relevant compliance requirements for TES for 2022 for which policies are being drafted related to the USDA RD Community Facilities Program loan include reporting, reserve account funding, and minimum insurance and bonding coverage, per the agreement with USDA. Specific controls over compliance with these requirements will be documented.
Finding no: 2022-002 Contact person(s) responsible: Jeff Mullaney, Director of Finance Corrective action planned: It will be policy moving forward that primary contact person(s) for federal awards shall remain consistent from receipt of award to close of said award. This will increase control over a...
Finding no: 2022-002 Contact person(s) responsible: Jeff Mullaney, Director of Finance Corrective action planned: It will be policy moving forward that primary contact person(s) for federal awards shall remain consistent from receipt of award to close of said award. This will increase control over award documentation and uses of funds. Additionally, a staff member who is not the primary contact for the federal award will perform an independent review of costs at each stage of the award reporting process to provide additional checks and balances. As it relates to the specific federal award in this audit period, management will replace unallowable costs with available allowable costs. Anticipated completion date: October 1, 2022
Finding Reference Number: 2022-001. Description of Concurrence or Nonconcurrence: The Organization agrees that 4 employees health insurance premiums were paid for after they were no longer employees of the organization. Corrective Action: The Organization has implemented an internal control where ...
Finding Reference Number: 2022-001. Description of Concurrence or Nonconcurrence: The Organization agrees that 4 employees health insurance premiums were paid for after they were no longer employees of the organization. Corrective Action: The Organization has implemented an internal control where a copy of every bill is now loaded to Bill.com for the bill approver to review the bill, which includes the health insurance and who should be receiving the insurance. Name of Contact Person: Ms. Edenausegboye Davis, Executive Director, 916-203-5777, edavis@dons.usfca.edu. Projected Completion Date: The above plan has been implanted and the organization will work with Sacramento Employment and Training Agency for next steps to reimburse the money.
View Audit 36890 Questioned Costs: $1
The Board will discuss these recommendations and consider implementing procedures to further segregate duties within our internal control system.
The Board will discuss these recommendations and consider implementing procedures to further segregate duties within our internal control system.
Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.
Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.
A. Comments on Findings and Recommendations: Finding 2022-001 Exit Counseling Condition: The Institution did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. PMC agrees with the condition outlined in Finding 2022-001 Exit Counseling. ...
A. Comments on Findings and Recommendations: Finding 2022-001 Exit Counseling Condition: The Institution did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. PMC agrees with the condition outlined in Finding 2022-001 Exit Counseling. B. Prior Audit Findings There were no findings in the prior audit. C. Corrective Action Taken on Findings Finding 2022-001 Exit Counseling Current processes for exit counseling are to ensure graduating students receive exit counseling during the final quarter of enrollment as well as receive an e-mail with directions on how to complete exit counseling at www.studentloans.gov from the financial aid department. Students that are enrolled in less-than-halftime credits are also provided exit counseling when the quarter starts or known when the student drops down to that enrollment status through reduction of courses. When students withdraw they will be notified that they are to confirm whether or not a student has received direct loans or not; if yes, they are to perform their exit counseling duties. There has been a lack of quality assurance that has led to exit counseling being completed after 30 days for a variety of reasons. To correct this issue, PMC Registrar will run an enrollment status change report on a bi-weekly basis to catch any student that has changed to an out-of-school status and/or a less-than-half-time status to ensure the financial aid department completes their exit counseling phone call or in-person meeting, as well as their exit counseling e-mail with information regarding completing exit counseling via www.studentloans.gov. Within seven (7) days of the report being run, each student file will be checked to ensure exit counseling was completed and notes are placed within the file to verify exit counseling was completed within the 30 day period of the enrollment status change as required.
EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2022-020 Medicaid Cluster, COVID-19 ? Medicaid Cluster, Children?s Health Insurance Program ? Assistance Listing No. 93.775, 93.777, 93.778, 93.767 ...
EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2022-020 Medicaid Cluster, COVID-19 ? Medicaid Cluster, Children?s Health Insurance Program ? Assistance Listing No. 93.775, 93.777, 93.778, 93.767 Action taken in response to the finding: MassHealth agrees with the recommendation and notes that all the identified findings relate to MassHealth?s Dental Third-Party Administrator DentaQuest. To address the findings and recommendation, MassHealth will require DentaQuest to implement a corrective action plan to review and improve internal controls for the retention of provider enrollment documentation. As part of this corrective action plan, MassHealth will require DentaQuest to ensure that all required documents are obtained and retained during validation and revalidation processes for both individual and group practices. To support this, DentaQuest will also be required to provide additional training to its provider enrollment staff on document retention. Name of the contact person responsible for corrective action: Tuyen Vu, Dental Program Manager Planned completion date for corrective action plan: EHS plans the completion date for the corrective action plan in July 2024.
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-019 Low-Income Home Energy Assistance, COVID-19 ? Low-Income ...
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-019 Low-Income Home Energy Assistance, COVID-19 ? Low-Income Home Energy Assistance ? Assistance Listing No. 93.568 Action taken in response to the finding: The Department of Housing and Community Development (DHCD) implemented new policies and procedures for LIHEAP reporting requirements necessary to ensure the reports are submitted timely and with accurate data to US HHS reporting systems. The DHCD Community Service Unit Manager, or their delegee, will coordinate with the LIHEAP Coordinator and/or other staff as needed to track deadline dates for all LIHEAP reports. Additionally, prior to submission all reports will be reviewed and verified against data sources by a Community Service staff member not involved in the creation of the reports. Name of the contact person responsible for corrective action: Ed Kiely, Community Service Unit Manager Planned completion date for corrective action plan: June 1, 2023
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-015 COVID-19 ? Emergency Rental Assistance ? Assistance Listing No. 21.023 ...
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-015 COVID-19 ? Emergency Rental Assistance ? Assistance Listing No. 21.023 Action taken in response to the finding: As of June 2022, monthly reports are no longer required for ERA. All reports will be uploaded to treasury before the deadline. Name of the contact person responsible for corrective action: Molly Butman Planned completion date for corrective action plan: April 10, 2023
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-011 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 ...
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-011 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Reporting has been built to notify responsible parties of the award periods of performance and highlight any issues for corrective action in accordance to previously filed FFATA reporting. In addition, FFATA reporting has been created in EOLWD?s DataMart application. Actions taken are as follows: ? Performed FFATA training ? Created accounts for employee access to FFATA ? Filed existing outstanding and new grant FFATA reports ? Used new reporting to notify responsible parties that a new grant/modification has arrived and requires a FFATA Subaward report filed ? Training for existing staff complete and new staff will be trained accordingly as part of their onboarding. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants, EOLWD Planned completion date for corrective action plan: June 30, 2023
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-010 WIOA Cluster ? Assistance Listing No. 17.258, 17....
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-010 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Staffing: Two new Budget Analysts will begin working for EOLWD at the end of June in 2023. These analysts will provide additional capacity for filing 9130s for WIOA. Training: In March and April 2023, EOLWD provided training to new staff on the preparation, certification, and submission of 9130 reports. Staff beginning in June 2023 will be trained during the next 9130 reporting period. Automating Business Practices: EOLWD refined its automated 9130 reporting for the March 31, 2023, reporting period and is finalizing further refinements that will be implemented prior to the next quarterly reporting period. Standard Operating Procedures: EOLWD developed job aides for the preparation of 9130 reports with its new automated processes and is in the process of drafting new Standard Operating Procedures (SOP). These SOPs will be finalized and submitted to DOL by October 1, 2023, as outlined in the corrective action plan schedule provided to DOL. An updated version of this schedule is provided below. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants, EOLWD Planned completion date for corrective action plan: October 1, 2023
Finding 34600 (2022-001)
Significant Deficiency 2022
Corrective Action Plan The University of Tulsa Student Financial Services External Audit: Academic Year 21/22 During the spring 2022 semester, The University of Tulsa closed for a 5-day period due to inclement weather. The Return of Title IV (R2T4) calculations that were conducted adjusted total...
Corrective Action Plan The University of Tulsa Student Financial Services External Audit: Academic Year 21/22 During the spring 2022 semester, The University of Tulsa closed for a 5-day period due to inclement weather. The Return of Title IV (R2T4) calculations that were conducted adjusted total number of days in the semester; but did not adjust total days attended on the R2T4 calculations. The University of Tulsa reviewed all R2T4 calculations for spring 2022 with a withdraw date of February 2 or after. 11 recalculations were required, funds are being returned to the Department of Education. For future semesters, the formula for breaks will be hard coded into the COD R2T4 formula for all new breaks in the event of school closure during a semester to avoid missing either a reduction in the numerator or denominator. Name of the contact person responsible for corrective action: Vicki Hendrickson, Director, Student Financial Services
View Audit 35438 Questioned Costs: $1
Finding 2022-001: Federal Program: Community Facilities Loans and Grants Cluster: Community Facilities Loans and Grants Assistance Listing Number: 10.766 Criteria: Section 4.4 of the Community Facilities Direct Loan agreement stipulates that the borrower must maintain funds in accounts in accord...
Finding 2022-001: Federal Program: Community Facilities Loans and Grants Cluster: Community Facilities Loans and Grants Assistance Listing Number: 10.766 Criteria: Section 4.4 of the Community Facilities Direct Loan agreement stipulates that the borrower must maintain funds in accounts in accordance with Section 4 of the Loan Resolution. The Loan Resolution stipulates that the borrower must establish a General Account and Reserve Account. The Reserve account must be funded to an amount equaling or exceeding $1,167,219. Condition and Context: The Association did not have a specific Reserve Account established in accordance with the Loan Resolution. Corrective Action Plan: Corry Memorial Hospital Association d/b/a LECOM Health Corry Memorial Hospital and Subsidiaries agrees with the finding and will implement controls sufficient to identify and monitor ongoing compliance with requirements. Additionally, Corry Memorial Hospital Association d/b/a LECOM Health Corry Memorial Hospital and Subsidiaries will establish and fund the required reserve account. Contact Person: Tim McGahen, Chief Financial Officer 965 Shamrock Lane, Corry, PA 16407 Expected Date of Resolution: The policies are expected to be updated effective March 30, 2023. The Reserve account is expected to be established and funded by March 1, 2023.
FINDING 2022-002 Contact Person Responsible for Corrective Action: Sherry Lockard Contact Phone Number: 812-283-1500 Views of Responsible Official: The Town concurs with the finding. Description of Corrective Action Plan: The Town has assigned the duties to request reimbursement (LPA Invoice Voucher...
FINDING 2022-002 Contact Person Responsible for Corrective Action: Sherry Lockard Contact Phone Number: 812-283-1500 Views of Responsible Official: The Town concurs with the finding. Description of Corrective Action Plan: The Town has assigned the duties to request reimbursement (LPA Invoice Voucher) from the IN Dept of Transportation to the Office Manager of Public Works. The Office Manager will prepare the LPA Invoice Voucher for INDOT and one of the two ERC?s, Public Works Director, or Assistant Public Works Director, will review for accuracy and sign off on the LPA Invoice Voucher. Anticipated Completion Date: May 9, 2023
FINDING 2022-003 Subject: Staffing for Adequate Fire and Emergency Response (SAFER) Contact Person Responsible for Corrective Action: Dustin Dillard Contact Phone Number: 812-331-1906 Views of Responsible Official: We understand and agree with the importance of internal controls and segregation of d...
FINDING 2022-003 Subject: Staffing for Adequate Fire and Emergency Response (SAFER) Contact Person Responsible for Corrective Action: Dustin Dillard Contact Phone Number: 812-331-1906 Views of Responsible Official: We understand and agree with the importance of internal controls and segregation of duties at the District and we believe our policies, procedures, individual job descriptions and management oversight fulfill these necessary requirements, we intend to comply with the suggestions made by the auditing staff. Description of Corrective Action Plan: The SAFER Reimbursement Request spreadsheets are prepared by two administrative personnel who perform checks and balances on calculations, payroll reports, time-keeping reports and employee roster changes before submitting the information to the Fire Chief for review and submission. The District now requires both Administrative personnel to sign and date a cover sheet upon completion of the compilation. The Financial Administrative Assistant will reconcile the data entered into the FEMA portal by the Chief by initialing a printed copy of the dated request. Anticipated Completion Date: To be implemented with all future reimbursement requests following this date 8-23-23 More information about this finding is available in the Supplemental Report.
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