Corrective Action Plans

Responsible Contact Person(s): Barry Davis, Chief Information Security Officer and Information Security & Risk Management Kevin Platea, Chief Information Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 12/31/2023

Responsible Contact Person(s): Steve Hanoka, Chief Information Security Officer Corrective Action Planned: Policies are reviewed and signed. Procedures are in progress, to be followed by implementation. DMAS wants to meet with the APA and VITA to discuss Pen Test and vulnerability scan processes. Completion of System Security Plans (SSPs) are about 50% complete, with 6 SSPs complete, 3 under review, 1 in draft and 7 to schedule. A program management policy/standard has been written and is under review. Estimated Completion Date: 4/1/2024

FINDING 2023-004 Finding Subject: COVID-19 - Education Stabilization Fund – Reporting Summary of Finding: Reports were not reviewed by someone other than the preparer Contact Person Responsible for Corrective Action: Todd Nobbe Contact Phone Number: 812-934-2194 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedure to ensure report are review by someone other than the preparer. Completion Date: Immediately 2/26/2024

FINDING 2023-003 Finding Subject: Title I Grants to Local Educational Agencies Special Tests and Provisions – Assessment System Security Summary of Finding: A sample of 40 employees were tested from the school’s roster and ten did not have a signed agreement indicating training was received. There was no process to ensure that all employees required to be trained received the training and submitted the Assessment System Security Agreement. It is recommended that the School Corporation's management establish a system of internal controls. Contact Person Responsible for Corrective Action: James H. Hardman Contact Phone Number and Email Address: 219-663-3371 jhardman@cps.k12.in.us Views of Responsible Officials: The management of the Crown Point Community School Corporation concurs with the finding. Description of Corrective Action Plan: The management of the Crown Point Community School Corporation will establish a system of internal controls to ensure all employees required to be trained receive the training and submit the Assessment System Security Agreement. Anticipated Completion Date: February 20, 2024

FINDING 2023-002 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: The School Corporation had established a system of internal controls over the Final Expenditure report for Title I. However, the internal control process was not documented. It is recommended that the School Corporation's management establish a system of internal controls. Contact Person Responsible for Corrective Action: James H. Hardman Contact Phone Number and Email Address: 219-663-3371 jhardman@cps.k12.in.us Views of Responsible Officials: The management of the Crown Point Community School Corporation concurs with the finding. Description of Corrective Action Plan: The management of the Crown Point Community School Corporation will establish a system of internal controls consisting of policies and procedures. Anticipated Completion Date: April 5, 2024

FINDING 2023 004 Finding Subject: Child Nutrition Cluster – Allowable and Non allowable Activities and Costs Summary of Finding: Material Weakness FCSC did not have a review process in place to ensure that food service program funds were being used for allowable activities and allowable costs. Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825 2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. However, it has never been a past practice to audit the costs and activities of the food service program. This has been a recent change in audit requirements that began with the beginning of this audit period. Description of Corrective Action Plan: The Deputy Treasurer will randomly and periodically request receipts from the food service director in order to conduct a “mini audit” to ensure that all costs and activities are, in fact, allowable. Anticipated Completion Date: A new procedure is in place effective February 2024. The documented oversight will be available and provided for review with the 2025 audit.

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Corban has appointed an experienced individual in Financial Aid to periodically review modular students’ R2T4 calculations, review returns, and conduct training. These important actions will ensure the preservation of perishable knowledge, while also promoting the acquisition of knowledge of new developments within the sector. Person Responsible for Corrective Action Plan: Jordan Lindsey, Associate Vice President for Enrollment Management and Marketing Anticipated Date of Completion: April 30, 2024

Finding 2023-003: Allowable Cost/Cost Principles and Reporting Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 4 TIN#237224698 Federal Financial Assistance Listing Number: 93.498 Finding Summary: Imagine the Possibilities, Inc. final eligible expenditure listing identified as eligible and claimed under the Provider Relief Fund program was not reviewed and approved by a separate individual outside of the preparer. In addition, the Organization’s special report submitted to the Department of Health and Human Services for Period 4 TIN #237224698 was not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. The Organization will review the internal controls and implement improvements related to allowability of all federal cost claimed, including those regarding the identification of duplicate items and approved costs. Anticipated Completion Date: March 31, 2024

Finding 2023-002: Preparation of Schedule of Expenditures of Federal Awards Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provide Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year Period 4 TIN#237224698 Medicaid Cluster Federal Financial Assistance Listing Number: 93.498 & 93.778 Finding Summary: The Organization does not have an internal control system designed to provide for a complete and accurate schedule being audited. Eide Bailly LLP was requested to draft the schedule and notes to the schedule. Responsible Individuals: Megan Simmons, CFO Corrective Action Plan: Management agrees with the finding. However, management feels that committing the resources necessary to remain current on SEFA reporting requirements and corresponding footnote disclosures would lack benefit in relation to the cost but will continue to evaluate on a regular basis. Anticipated Completion Date: March 31, 2024

FINDING 2023-003 Finding Subject: Education Stabilization Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSERI II reports and two ESSER III reports for a total of six reports. The reports were prepared and submitted by the Director of Finance without a documented oversight or review process. In addition, four of the six annual data reports were not supported by the School Corporation’s records. The financial information provided did not agree to the data submitted; therefore, we could not determine the accuracy of the annual data reports. Contact Person Responsible for Corrective Action: Camden Parkhurst Contact Person Phone Number and Email Address: 765-457-8101 camden.parkhurst@nwsc.k12.in.us View of Responsible Official: We concur with the finding. The submissions referenced without proper documentation were submitted by the previous CFO. The current finance staff is unable to locate any supporting documentation regarding those submissions. There is a reimbursement request internal controls document that was signed by both the CFO and Superintendent, but here is no supporting documentation to accompany it. Description of Corrective Action Plan: The current Director of Finance and finance team have attached all supporting documentation from the financial software to their submissions along with an internal controls document signed by the Director of Finance and Superintendent. The corporation is actively working with the Department of Education to amend when it believes to be some errors in the prior submissions as well. Anticipated Completion Date: August 2024

FINDING 2023-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were to be prepared and submitted by the School Principal and reviewed by the Executive Business Director; however, no evidence of this review or oversight process could be provided. As such the annual data reports were prepared and submitted to IDOE without an oversight or review process to prevent or detect and correct errors. In addition, five of the six reports submitted during the audit period were not supported by the School Corporation’s records. The following errors were identified:  The ESSER I, Year 2 report, which had an applicable reporting period of October 1, 2020 through June 30, 201, reported $534,761 in expenditures. However, actual expenditures for the applicable reporting period totaled $478,883.  The ESSER 1, Year 3 report which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $243,814.67.  The ESSER II, Year 1 report, which had an applicable reporting period of July 1, 2020 to June 30, 2021, reported $733 in expenditures. However, actual expenditures for the applicable reporting period totaled $322,539.  The ESSER II, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $276,642.  The ESSER III, Year 2 report, which had an applicable reporting period of July 1, 2021 to June 30, 2022, reported $0 in expenditures. However, actual expenditures for the applicable reporting period totaled $1,315,208. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify segregation of duties for Federal Fund Coordinators, employees responsible for calculating accurate disbursement reports and reimbursement requests. Detailed expenditure reports will be generated for end of year reporting with the Accounting Specialist, Accounts Payable Coordinator and the Executive Director of Business Services completing a final review process providing signatures indicating review and accuracy before filing. Anticipated Completion Date: March 1, 2024.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Summary of Finding: Condition and Context Direct charges to a federal award are to be for allowable costs and made in conformance with the applicable cost principles. Payroll benefits were entered by the payroll department and reviewed by the Payroll Coordinator to ensure proper payment. However, this review was not completed on a detailed level by employee to ensure the payroll withholdings, deductions, and benefits retained from employees’ wages were for allowable costs and made in conformance with applicable cost principles. The lack of internal controls was a systemic issue throughout the audit period. Contact Person Responsible for Corrective Action: Dr. Thomas A. Keeley, Executive Director of Business Services Contact Phone Number and Email Address: (574) 258-9591 Tkeeley@phm.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will revise job descriptions to clearly identify tasks and responsibilities for the payroll process. The school corporation will print a detailed employee wage report for each payroll with double signatures indicating a thorough review process by the payroll coordinator and the payroll accounting specialist/Food Service Manager. Finally, the Executive Director for Business Services will complete noting a final review of corresponding benefits withholdings to the corresponding vendor payments indicating the process is complete with an official signature. Anticipated Completion Date: March 1, 2024.

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2023-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2022-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compliance to review federal award provisions and requirements, evaluate risks of noncompliance, and respond to such risks through internal controls. The process should include methods to identify and communicate changes to federal award requirements to all key individuals within the Organization and to verify internal controls are implemented correctly and are operating effectively. Planned Corrective Action: As the organization has grown, compliance of federal programs has become decentralized. We agree that additional resources need to be added to ensure compliance with all state and federal awards. The Organization has added additional capacity to the Business Office to assume the compliance and reporting responsibilities. Michelle Krauter, the Director of Accounting & Finance, is responsible for ensuring fiscal compliance and will coordinate program compliance activities with the Heads of School at each campus and the Directors of Academic Accountability. Through the monitoring activities conducted by the Indiana Department of Education during 2023, staff gained a better understanding the compliance requirements and are implementing processes to ensure ongoing adherence to the requirements. Evaluation of these processes will continue through 2024. 43

Finding 2023.002 Response: The information reported on filing for Period 6 will be reviewed internally by others in the Finance department to ensure the expenses are reported accurately. Responsible Party: Terry Lutz, CFO at Scheurer Hospital Estimated Completion: 03/31/2024

Finding 2023.001 Response: Scheurer Hospital plans to save the documentation noting the overstated expenses along with the unused lost revenue in the audit file. In the event of a further audit, Scheurer Hospital will have the documentation to support the federal awards expended. Responsible Party: Terry Lutz, CFO at Scheurer Hospital Estimated Completion: 02/21/2024

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. Findings – Federal Award Program Audit Finding 2023-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Catalog Numbers: 14.871 and 14.879 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers Program - No Mainstream Vouchers Program - Yes Material Weaknesses in Internal Control over Compliance for Eligibility for the Mainstream Vouchers Program Significant Deficiency in Internal Control over Compliance for Eligibility Section 8 Housing Choice Vouchers Program Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 5,295 units. Of a sample size of seventy-one (71) tenant files, the following was noted: • HUD 9886 Form was missing in 1 file • Annual HUD 50058 recertification form and related verification of income and assets was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: • Mainstream Vouchers $19,830 • Section 8 Housing Choice Vouchers Program $1,875 Cause: There is a significant deficiency in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Section 8 Housing Choice Vouchers Program. There is a material weakness in compliance for the eligibility type of compliance related to the maintenance of tenant files in the Mainstream Vouchers Program. The Authority has not properly maintained tenant files in compliance with program requirements following the expiration of HUD waivers. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. The Mainstream Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement a corrective action plan that will 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. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced a large backlog of reexaminations along with higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management developed and implemented a plan to rapidly work through the backlog, and has made significant progress to bring the program into compliance. The audit resulted in one missing consent form (HUD 9886), and one re-examination (HUD 50058), which is noted as missing. While the consent form had expired and a new consent form was required during the audit period, the income information collected for the household was collected while the consent form was still valid. With regards to the re-examination noted as missing, this re-examination was performed late, having been completed just six days after the end of the audit period. The re-examination was initiated on time, and the delay in completing the re-examination was caused by the program participant’s delay in providing the required documents. Additionally, the Authority has been selected for participation in the Moving to Work program ('MTW'). Alternative re-examination schedules, including biennial re-examinations, are an approved MTW activity allowable through the MTW Operations Notice. The Authority has received HUD approval of a waiver that allows the use of an alternate re-examination schedule effective July 1, 2023. This re-examination schedule is in effect currently and will be in effect for the entire duration of the subsequent audit period. Based on the transition to biennial and triennial re-examinations, the Authority has already come into compliance with timely recertifications. Further, the Authority management is in the process of implementing enhanced Quality Control procedures, with staff to conduct ongoing internal audits over the course of the year. If the U.S. Department of Housing and Urban Development has any questions regarding this plan, please call Aaron Pomeroy, Finance Director at 831-454-5908.

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Utility Allowance Schedule Type of Finding: Instance of Non‐Compliance and Material Weakness in Internal Control over Compliance Views of Responsible Officials: The Housing Authority fully complied with 24CFR 982.517(C)(1) of HUD regulations that states that "A PHA must review its schedule of utility allowances each year and must revise its allowance for a utility category if there has been a change of 10 percent or more in the utility rate since the last time the utility allowance schedule was revised. The PHA must maintain information supporting its annual review of utility allowances and any revisions made in its utility allowance schedule." Each year, the Housing Authority hires a consultant to analyze the Utility allowances for the Fairfield jurisdiction. Once that assessment is completed, Housing Authority staff and Management review it. The Housing Authority staff then meets with the Consultant to discuss any irregularities found or resolve questions emanating from its review. Once staff and Management are satisfied with the information, have clear documentation explaining the Consultant's conclusions, and memorialize any categories that have changed 10% or more, Management will finalize its review of the Utility Allowance Schedule. The Housing Authority will document Management’s approval of the utility allowance adjustments, if any. Responsible Individual(s): Tanya Tran, Housing Division Manager LaTanna Jones, Deputy Executive Director Anticipated Completion Date: June 1, 2024

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Section 8 Housing Choice Voucher Cluster Federal Assistance Listing Number: 14.871 Pass‐through: N/A Award No. and Year: CA065‐2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials: We concur. The Housing Authority addressed this issue when the City was informed in March 2023 there was not enough documentation prior to online grant reporting for the auditors to verify grant reports were reviewed prior to submission on other grants being audited. The Housing Authority has continuously maintained a check and balance approach for preparing and reviewing VMS reports before HUD submission. All reports are prepared by the Housing Authority and finance staff, then reviewed by either the Housing Authority Manager or the Deputy Executive Director before submission to HUD. The reviewer is now documenting their review prior to submitting the VMS reports. Responsible Individual(s): Tanya Tran, Housing Division Manager Anticipated Completion Date: June 30, 2023

Federal Agency: U.S. Department of Homeland Security Program/Cluster: Staffing for Adequate Fire & Emergency Response Federal Assistance Listing Number: 97.083 Pass‐through: N/A Award No. and Year: EMW‐2020‐FF‐00816, 2020 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials and Corrective Action Plan: The Fire Department has addressed this issue when the City was informed in March 2023 there was not enough documentation prior to online grant reporting for the auditors to verify grant reports were reviewed prior to submission on other grants being audited. The two (2) submissions in question were reviewed and verified by management but were not documented for the auditors to verify when the review was completed, prior to the City being notified in March 2023 to further document the review process. The City has implemented this recommendation. Responsible Individual(s): Taylor Armour, Administration Division Manager Anticipated Completion Date: June 30, 2023

Finding 2023-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2024 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the financial reporting and close processes to determine whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Action Taken: Cheney Care Community will review their internal controls over the financial reporting and close processes to determine whether additional controls need to be implemented going forward.

Due to turnover of the Organization's Finance and Administration manager, the Organization was unable to have the annual audit completed within the required timeframe, and subsequently were also late in submission of the FAC report. The Organization has internally hired a Staff Accountant and an Accounts Payable to assist with audit preparation. The Organization has externally contracted an accounting firm that has provide the Organization with a CPA to conduct audit preparation and other financial services, as requested. We can confirm that this is not a repeat finding but an isolated instance. The Organization will work on getting financial information timelier (i.e. submit the reporting package with the guidelines of Uniform Guidance).

FINDING 2023-005 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent and reviewed by the Treasurer prior to submission. However, this review process was not effective and did not detect and allow correction of errors prior to submission. All six of the submitted reports were selected for testing. Four of the reports were not supported by the unit's records. The financial information provided did not agree to the data submitted in the reports; therefore, we could not determine the accuracy of the reports. The lack of controls was systematic throughout the audit period. The noncompliance was isolated to the four reports identified above. The auditors recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are supported by the ledgers or reports used to complete the report Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation is required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted includes, but is not limited to, current period expenditures, prior period expenditures, and expenditures per activity. The annual data reports will be complied/prepared by the Treasurer and the Assistant Superintendent to ensure the reports are supported by the corporation’s financial data. The JotForm will be reviewed by the Superintendent prior to submission. Anticipated Completion Date: 2/21/2024

FINDING 2023-003 Finding Subject: Special Education Cluster (IDEA) – Allowable Costs/Cost Principles Summary of Finding: The Individuals with Disabilities Act (IDEA) Special Education – Grants to States program provides grant to states, and through them to Local Educational Agencies (i.e. the School Corporation), to assist them in providing special education and related services to eligible children with disabilities ages 3-21. IDEA’s Special Education – Preschool Grants program provides grants to states, and through them to LEAs to assist them in providing special education and related services to children with disabilities ages three to five and, at the state’s discretion, to two-year-old children with disabilities who will turn three during the school year. To receive reimbursement for special education expenses paid, the School Corporation’s Treasurer completed a reimbursement request, and the Assistant Superintendent reviewed it. The documentation attached to the reimbursement request; however, did not have adequate detail to determine the payroll paid was in conformance with the applicable cost principles. Furthermore, payroll disbursements were posted by the Treasurer without a review to ensure the payee, amount, fund, and disbursement classification was accurate prior to disbursement. The auditors recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Rolland Abraham Contact Phone Number and Email Address: 765-584-1401, rabraham@randolphcentral.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Treasurer will prepare a detailed payroll appropriation report each payroll. The Assistant Superintendent will review it to ensure the payee, amount, fund, and disbursement classification are accurate prior to disbursement. After approval, at the end of the month, the Treasurer will complete a reimbursement request and the Assistant Superintendent will review it for accuracy prior to submission. Anticipated Completion Date: 2/21/2024

Finding 2023-006: Voucher Management System Reporting NHA Corrective Action: In process. The fee accountant will now complete the VMS report monthly. The executive director will review these reports monthly. The executive director will conduct an annual review of VMS at the YE closing in June (done in July or August prior to FDS submission) and before HUD pulls VMS data for annual renewal funding (usually done in January). This will ensure that all VMS data is reviewed by both management and the fee accountants, increasing the likelihood that any error will be caught and corrected in a timely manner.