Corrective Action Plans

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Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Te...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with its third-party servicer and implement procedures to ensure that enrollment data, changes in status, and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office has temporarily taken over the administration of this process due to personnel changes in the Registrar’s Office. Enrollment reports are scheduled to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. An internal audit will be conducted using the third-party Audit Guide and will be documented. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for a corrective action plan: Immediate Implementation
Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisio...
Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023
Finding 2003-006: We agree with the finding. The Authority will adopt an operating budget for the Voucher program as a control to ensure operating costs are reasonable and the program remains financially viable. The Authority will put into place a system to reimburse shared expenses in a timely man...
Finding 2003-006: We agree with the finding. The Authority will adopt an operating budget for the Voucher program as a control to ensure operating costs are reasonable and the program remains financially viable. The Authority will put into place a system to reimburse shared expenses in a timely manner and will monitor the balances. The Authority will no longer grant temporary loans to other Authority programs, to be completed within thirty days.
Finding 2003-005: We agree with the finding. The Authority will enter into a General Depository Agreement HUD-51999 (GDA) with our financial institution within the next thirty days.
Finding 2003-005: We agree with the finding. The Authority will enter into a General Depository Agreement HUD-51999 (GDA) with our financial institution within the next thirty days.
Finding 2003-004: We agree with the finding. However, the Authority can not reasonably adopt internal control procedures to correct the material weakness.
Finding 2003-004: We agree with the finding. However, the Authority can not reasonably adopt internal control procedures to correct the material weakness.
As of August 2023, BBBSC implemented controls that properly support the distribution of personnel charges in accordance with the Uniform Guidance and employees’ salaries charged to the grant are based on actual costs incurred. Further, these charges are reviewed by the Director of Finance before fed...
As of August 2023, BBBSC implemented controls that properly support the distribution of personnel charges in accordance with the Uniform Guidance and employees’ salaries charged to the grant are based on actual costs incurred. Further, these charges are reviewed by the Director of Finance before federal reimbursements are requested.
View Audit 291540 Questioned Costs: $1
January 31, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 458 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 ...
January 31, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 458 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT None. FINDINGS-FEDERAL AWARD PROGRAMS AUDIT 2023‐001 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Education Program Name: Special Education Cluster (IDEA Assistance Listing Numbers: 84.027 and 84.173 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. Contact Name – Tyler Bacon Expected Completion Date -06/30/2024 If the U.S. Department of Education has questions regarding this plan, please call Tyler Bacon at 913-724-1396. Sincerely yours, Tyler Bacon Business Manager/Board Clerk Unified School District No. 458
Finding 2023-001- Eligibility Condition During our audit, 8 out of 40 individual files selected for eligibility testing did not contain evidence that the Organization obtained or reviewed a lease to support the eligibility of the individual who received a direct assistance payment. Further, there ...
Finding 2023-001- Eligibility Condition During our audit, 8 out of 40 individual files selected for eligibility testing did not contain evidence that the Organization obtained or reviewed a lease to support the eligibility of the individual who received a direct assistance payment. Further, there was no evidence of alternative documentation of residence when a lease could not be obtained. Corrective Action Plan Corrective Action Planned: Catholic Charities Diocese of Allentown declined to administer the second round of ERAP funding. Significant leadership changes have been implemented in May 2023, including a new Managing Director. Catholic Charities is in the process of designing an enhanced training program to ensure all programs complete all documentation required to substantiate eligibility under each program administered, whether privately or publicly funded. Name(s) of Contact Person(s) Responsible for Corrective Action: Andrea Kochen Neagle, Managing Director and Susan Mazza, Finance Administrator Anticipated Completion Date: December 2023
View Audit 291476 Questioned Costs: $1
Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers & Mainstream Vouchers Assistance Listing Number: 14.871 & 14.879 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Mat...
Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers & Mainstream Vouchers Assistance Listing Number: 14.871 & 14.879 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not properly abate four (4) out of twenty-six (26) annual failed inspections selected for testing. Context: The Authority did not properly abate four (4) out of twenty-six (26) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Our sample size is statistically valid. Known Questioned Costs: $12,804 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance with Notice PIH 2021-14(HA). Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs are in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the compliance requirements of the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs. Jeremy White, HCV Director, will be responsible to implement this corrective action by March 31, 2024.
View Audit 291328 Questioned Costs: $1
Finding 2023-005 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Descript...
Finding 2023-005 – Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, primary and secondary review of all federal accounts payable claims. Anticipated Completion Date: 02/16/2024
Finding 2023-004 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school c...
Finding 2023-004 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of eligibility determinations to ensure they meet the grant agreement and eligibility compliance requirements. Anticipated Completion Date: 08/31/2024
Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corp...
Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of the reporting to ensure they are meeting the grant agreement and cash management compliance requirements. Anticipated Completion Date: 02/16/2024
View Audit 291176 Questioned Costs: $1
Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. ...
Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims, and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 02/16/2024
The District agrees with the finding and the recommendations of the auditors. The District has taken a number of steps to improve internal controls and will finalize a comprehensive plan for robust internal controls reinstatement by January 10, 2024. Since the arrival of new Human Resources Leadersh...
The District agrees with the finding and the recommendations of the auditors. The District has taken a number of steps to improve internal controls and will finalize a comprehensive plan for robust internal controls reinstatement by January 10, 2024. Since the arrival of new Human Resources Leadership in the fall of 2022, steps have been taken to ensure that all employee contracts are kept on file in hard copy and digital. The missing files occurred during a transition period during the hire and rehire period of spring and summer 2022, before the arrival of new leadership. At this time, the Human Resources department ensures redundancy of storage of these contracts, with both paper copies and digital copies of all signed contracts kept in secure spaces. A staff member is charged to ensure these are all filed, and the Supervisor does an internal audit to ensure safekeeping. Going forward, the Human Resources Director will conduct quarterly checks, in May, August, November, and February to ensure all files are in place.
Audit Finding Reference: 2023-001 Management's View and Planned Corrective Action: Due to the extension of the federal funding for free school meals in the prior year, the District is aware of the fund balance greater than three (3) months of its average expenditures. We are looking to reserve the p...
Audit Finding Reference: 2023-001 Management's View and Planned Corrective Action: Due to the extension of the federal funding for free school meals in the prior year, the District is aware of the fund balance greater than three (3) months of its average expenditures. We are looking to reserve the program fund balance to support the potential renovation that will take place over the summer of 2024 should Warrant Article 6 Renovate the Checkers Kitchen at Alvirne pass. This special warrant article is recommended by both the Hudson School Board and Budget Committee. This is allowable from the NH Department of Education's Office of Nutrition Programs and Services (ONPS). Name of Contact Person and Completion Date: Karen Atherton, Food Service Director Melissa Van Sickle, Finance Director Anticipated completion date: If supply issues are not a factor, December 31, 2024; otherwise, June 30, 2025.
View Audit 291088 Questioned Costs: $1
Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Fi...
Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Final Expenditure Reports were reopened and completed on September 11, 2023. Further, the District acknowledges the lack of timeliness of submitting the Final Expenditure Reports, and has implemented procedures to ensure all reporting surrounding final expenditures is completed and submitted to granting authority in accordance with terms of the agreement going forward. Contact person responsible for corrective action: Erica Ingles, Finance Director and Jennifer Mudge, Supervisor of School Improvement and Grant Programs Anticipated Completion Date: 9/11/2023
2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation th...
2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation that they are properly authorized. All employees should have timesheets to support the hours worked and charged to the grant. These timesheets should be formally approved by a supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women of Nations has updated its payroll policies and procedures to ensure that time and effort certifications are completed correctly and approved in a timely manner by supervisors. Name(s) of the contact person(s) responsible for corrective action: Charles Nelson Planned completion date for corrective action plan: June 1, 2023
View Audit 290620 Questioned Costs: $1
Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion...
Gramm Leach Bliley Act (GLBA) Compliance Planned Corrective Action: The college has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Jon Kokos, CFO Anticipated Date of Completion: June 30, 2024
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the cor...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The director is performing the R2T4 calculation, returning funds (if necessary), adjusting the student’s awards and bill in the appropriate software. The senior associate director is reviewing each student to be certain the correct funds are being reduced and/ or returned based on the calculation. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process is being implemented for the 2023-24 academic year.
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...
Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ellucian, the producer of Banner, had a known defect that caused incorrect status change dates to be inserted in the Banner program which processes student enrollments. This defect was not known to me at the time, therefore, it was not something I was aware to be looking for when completing enrollment reporting. There were no errors which would have alerted me to the issue. See case PB006205. Known defect now seems to be corrected. Will review current processes in order to ensure the continuance of timely and accurate reporting, and to eliminate the possibility of future errors being at the fault of the University. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: 4/1/24
Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon...
Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Jim Holifield Contact Phone Number: 219-531-3007 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon wage rate requirement language has been added to all bid packets and quote solicitations. The Educational Support Coordinator and Deputy Treasurer will work with VCS Department Directors to monitor all federally-funded construction projects for compliance with said language. Anticipated Completion Date: February 1, 2024
Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year....
Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year. CLA also recommends that the Center keep track of relevant due dates to insure timely submittal of reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: PPG reports were submitted on time whenever possible however there were instances where changes were requested and there were subsequent reports which made the submission date appear to be tardy. For future clarification, the staff will add date submitted on the bottom of those reports to be saved in our own database with additional dates for 2nd or 3rd submissions due to change requests. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Planned completion date for corrective action plan: Staff will add date submitted to the Quarterly reports already submitted for the 23/24 year and will include the submittal date to all future quarterly reports for ppg and all reports requested by managing entity. If the Oversight Agency has question"s regarding this plan, please call Angie Ellison at (863) 802-0777 .
Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Expla...
Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Match reports are input into a data document that includes providers in 14 counties. For this reason, our managing entity was requested to send our version without the other counties. The wrong version was sent (quarter 3 instead of final year end version) therefore from this date forward we will keep each quarterly version in our database with added line items that list the preparer and tile approval w/date. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Immediate: Staff will go back to quarter 1 of 23/24 year and make these changes with copies in database as well as preparer and approval lines w/date. These documents will be prepared in this fashion from this date forward.
Lack of Review Condition: During review of employee timesheets and related grant reimbursement requests, and annual match report, there was a lack of evidence of review of these documents. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating...
Lack of Review Condition: During review of employee timesheets and related grant reimbursement requests, and annual match report, there was a lack of evidence of review of these documents. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing reimbursement forms and match reports. We also recommend that those approving timesheets document their approval via a signature. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned: While some of these documents (example: match) are not in our control, we will save them in a file for our use with the added lines that include preparer's name, approval line and signature Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Planned completion date for corrective action Rian: All form revisions will begin March 1 2024
Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in ag...
Finding Number: 2023-001 Planned Corrective Action: See Below Anticipated Completion Date: 01/22/2024 Responsible Contact Person: Patricia Eddy, Treasurer The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the agreement with West Roofing to install and renovate the HVAC system at Columbia High School, which was January 7, 2021, ESSER funds were not awarded to the District. The District planned on using its Permanent Improvement funds (a non -federal program sourced fund) to pay West Roofing. The District initially paid West Roofing from the Permanent Improvement fund for the installation/renovation of the HYAC at Columbia High School as per the initial contract. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through ESSER funds. The prevailing wage was not met under the existing contract. The District has implemented the following Action Plan for Correction: 1. The Treasurer will ensure that all agreements intended to be sourced through Federal Funds will contain prevailing wage rate provisions prior to signing such agreements. 2. The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Funds, 3. The Treasurer will educate all responsible parties in the District regarding prevailing wage documentation to ensure appropriate documentation is obtained prior to payment to the contractors and prior to requesting Federal Funds.
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