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Finding Summary: Wallace Stegner Academy is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER f...
Finding Summary: Wallace Stegner Academy is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. Wallace Stegner Academy did not properly report the correct amount of ESSER expenditures by specific positions supported with GEER and ESSER funds and the number of full-time equivalent positions for all GEER and ESSER funds. Responsible Individuals: Accountant and Executive Director Corrective Action Plan: Management will provide the USBE with the correct amount of ESSER expenditures by specific positions supported with GEER and ESSER funds and the number of full-time equivalent positions for all GEER & ESSER funds. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.
Inaccurate TRIO Reporting Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.042A Finding Summary: Certain line items of the Annual Performance Report (APR) included inaccurate student information. Responsible Individuals: Jessica Thomp...
Inaccurate TRIO Reporting Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.042A Finding Summary: Certain line items of the Annual Performance Report (APR) included inaccurate student information. Responsible Individuals: Jessica Thompson, TRIO Project Director Corrective Action Plan: We agree with the auditors’ findings and recommendations. Previously, a spreadsheet was used to maintain student information for input in the APR. To ensure the most up to date information is used, this student information will now be input using the university student services account system. Additionally, the APR will be reviewed by the finance department prior to submission. Anticipated Completion Date: December 31, 2024
R2T4 Finding Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268, 84.063 and 84.007 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determin...
R2T4 Finding Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268, 84.063 and 84.007 Finding Summary: Errors in return to Title IV calculations: Calculations for five students included various errors. Errors included one late determination of withdrawal date (more than 30 days after the end of the period of enrollment), three returns completed more than 45 days after the withdrawal date, two incorrect percentage of aid earned calculations, and one overpayment to the Department of Education. Responsible Individuals: Tim Sechrist, Director of Financial Aid Corrective Action Plan: We agree with the auditors’ findings and recommendations. Financial Aid Office staff that will deal with withdrawals and returns will complete the FSA Training Webinar Videos for R2T4. These include the R2T4 Essentials and R2T4 Modules webinars available online. We will implement a second review of calculations with an additional staff member added to the process. We will have the Financial Aid Counselor review withdrawals as they are received and complete the preliminary calculation. The Counselor will pass the preliminary calculation to the Director of Financial Aid for review prior to processing the returns. We will work with the Online Learning Office to report and retain academic activity for distance education students. Anticipated Completion Date: December 31, 2024
Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and a...
Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation...
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have updated our procedure to reconcile Pell and Loans twice monthly to be able to catch any reporting errors within the 15-day reporting window. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024
Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of ...
Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. DaVinci Academy of Science and the Arts did not properly report the correct amount of all ESSER funds expended. Responsible Individuals: Business Manager and Executive Director Corrective Action Plan: Management will provide the USBE with the correct the amount of all ESSER funds expended. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.
Identifying Number: 2024-001 Finding: Untimely Submission of the Data Collection Form Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are com...
Identifying Number: 2024-001 Finding: Untimely Submission of the Data Collection Form Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are completed on a timely basis. The Business Office will continue to follow internal policies and procedures, including deadlines for fiscal year-end process. Contact Person Responsible for Corrective Action Plan: Frances A. LaBella, Associate Superintendent Completion Date: December 30, 2024
Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for ti...
Finding: 2024-003 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third‐party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. The University pushed through the changes in enrollment status to the Clearinghouse timely and accurately based upon the student’s enrollment status; however, the change in enrollment status was not pushed through all the way to NSLDS resulting in inaccurate and untimely records within NSLDS. Responsible Individuals: Kella Helyer, Director of Financial Aid and Amy Clark, University Registrar Corrective Action Plan: There is documentation of the student’s enrollment status in the National Student Clearinghouse (NSC) for each month starting Fall term 2023. The enrollment reporting process functions such that each month, the National Student Loan Data System (NSLDS) sends a file to NSC for the students who have been awarded federal aid. NSC then sends a file back to NSLDS for the students on the list. This return file then updates the NSLDS enrollment reporting section in their system. NSC will not send enrollment for students if they are not on the NSLDS list. To do so would be a FERPA violation. For the student in question, NSLDS did not place their name on the list for reporting enrollment until June 2024. A second call to NSLDS has been placed requesting a response as to why this student was not reported. Anticipated Completion Date: 12/6/2024
The Agency updated procedures for developing the SEFA in accordance with 2 C.F.R. 200.510 (b) to include the following process improvements: The agency has modified its current process in determining the value of federal awards expended for the various federal loans in Federal, which will include al...
The Agency updated procedures for developing the SEFA in accordance with 2 C.F.R. 200.510 (b) to include the following process improvements: The agency has modified its current process in determining the value of federal awards expended for the various federal loans in Federal, which will include all Federal loans within their affordability period in the compliance period. The compliance period requirements under the guidance §200.502 (b) are any new loans made or received during the audit period that are still within their affordability period. Add an additional process step regarding the requirements for the SEFA to be presented accurately when an expenditure is reclassified to another general ledger account across all programs to ensure the SEFA presentation accounts for the correct expenditures during the audit period. The agency has modified its current process to ensure the direct and indirect costs charged to the federal programs include only the costs incurred during the current fiscal year.
Finding 516255 (2024-001)
Significant Deficiency 2024
Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at th...
Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes. Anticipated Completion Date: May 31, 2025
2024-003 - Reporting U.S. Department of Housing and Urban Development – American Rescue Plan Act - MI Hope Grant (ALN 21.027); Passed through the Michigan State Housing Development Authority; All project numbers. Auditor Description of Condition and Effect. During our audit procedures over the Cit...
2024-003 - Reporting U.S. Department of Housing and Urban Development – American Rescue Plan Act - MI Hope Grant (ALN 21.027); Passed through the Michigan State Housing Development Authority; All project numbers. Auditor Description of Condition and Effect. During our audit procedures over the City's reporting process, we noted that there were discrepancies in the expenditures that were stated on the reports compared to the schedule of federal expenditures and the underlying accounting records. The City followed grant requirements to complete the financial, performance and compliance reporting as required by Treasury, however, the reports were inaccurate. Auditor Recommendation. We recommend that the City review reports submitted to ensure they are accurate. Corrective Action. The Finance Director will review all financial documents before they are submitted to outside agencies to ensure accuracy. Responsible Person: Bobbi Schoon, Director of Finance and Administration
The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10.
The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10.
Due to its size, it is not cost effective to hire additional staff to complete necessary reporting. Reviews and checks have been put into place prior to claim submissions with existing staff members.
Due to its size, it is not cost effective to hire additional staff to complete necessary reporting. Reviews and checks have been put into place prior to claim submissions with existing staff members.
Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to...
Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.
Condition: To determine that an accurate June 30, 2024 expenditure report was filed with the Illinois State Board of Education. The District reported expenses on the June 30, 2024 ESSER III expenditure report that were paid after year end. Recommendation: We recommend reconciling the general ledger...
Condition: To determine that an accurate June 30, 2024 expenditure report was filed with the Illinois State Board of Education. The District reported expenses on the June 30, 2024 ESSER III expenditure report that were paid after year end. Recommendation: We recommend reconciling the general ledger AP totals to the expenditure reports before submitting. Management Response: The District will add a verification process to reconcile the general ledger AP totals to the expenditure reports before submitting.
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submitting for more accurate reporting. Ma...
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submitting for more accurate reporting. Management Response: The District will review the general ledger to the expenditure reports before submitting.
Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to...
Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.
Condition: Expenditure reports for the ESF - Post Secondary Success grant were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management's Response...
Condition: Expenditure reports for the ESF - Post Secondary Success grant were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management's Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.
Condition: The District's general ledger totals are inconsistent with the ISBE reports due to timing errors, resulting in certain expenses being claimed too early and other expenses claimed too late on the IDEA Flow Through and Preschool grants. Recommendation: We recommend reconciling the general l...
Condition: The District's general ledger totals are inconsistent with the ISBE reports due to timing errors, resulting in certain expenses being claimed too early and other expenses claimed too late on the IDEA Flow Through and Preschool grants. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management's Response: The District will add a verification process to reconcile the general ledger totals to the expenditure reports before submitting.
Condition: The District overclaimed payroll expenses by $636 on their final grant report for IDEA Flow Through. Recommendation: We recommend reconciling the budgeted amount to the general ledger totals and reconciling those to expenditure reports before submitting. Management's Response: The Distric...
Condition: The District overclaimed payroll expenses by $636 on their final grant report for IDEA Flow Through. Recommendation: We recommend reconciling the budgeted amount to the general ledger totals and reconciling those to expenditure reports before submitting. Management's Response: The District will review the budgeted cost of items and the amount recorded in the general ledger against the expenditure reports before submitting.
View Audit 334032 Questioned Costs: $1
Condition: The District's general ledger totals are inconsistent with the ISBE reports due to timing errors, resulting in certain expenses being claimed too early and other expenses claimed too late on the IDEA Flow Through and Preschool grants. Recommendation: We recommend reconciling the general l...
Condition: The District's general ledger totals are inconsistent with the ISBE reports due to timing errors, resulting in certain expenses being claimed too early and other expenses claimed too late on the IDEA Flow Through and Preschool grants. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management's Response: The District will add a verification process to reconcile the general ledger totals to the expenditure reports before submitting.
Finding 516219 (2024-004)
Significant Deficiency 2024
Finding: 2024-003 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-004 Name of contact person: Corrective Action: Proposed Completion Date: Corrective actions for Finding 2024-001, 2024-002, 2024-003, and 2024-004 also apply to State award findings. Finding: 2024-00...
Finding: 2024-003 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-004 Name of contact person: Corrective Action: Proposed Completion Date: Corrective actions for Finding 2024-001, 2024-002, 2024-003, and 2024-004 also apply to State award findings. Finding: 2024-005 Name of contact person: Lindsey Cearlock Corrective Action: Proposed Completion Date: Immediately. To review all grant documentation carefully and ensure the County is compliant with all requirements. Section IV - State Award Findings and Questioned Costs Jessica Wall, Director YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 50 cases to verify that appropriate requests for informaiton are made. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recertifications that would ensure that appropriate information requests have been made and evaluated. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of information requests. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 50 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24. Supervisors will provide staff with a report at least once per month that includes terminated SSI cases that require a full eligibility evaluation. Staff will return this report each month with their initials to indicate that they have initiated full evaluations. Training will be provided by 11/30/24. Training will be provided by 11/30/24 and staff will received SSI Termination Report by 11/30/24. Jessica Wall, Director
Finding 516218 (2024-003)
Significant Deficiency 2024
Finding: 2024-003 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-004 Name of contact person: Corrective Action: Proposed Completion Date: Corrective actions for Finding 2024-001, 2024-002, 2024-003, and 2024-004 also apply to State award findings. Finding: 2024-00...
Finding: 2024-003 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-004 Name of contact person: Corrective Action: Proposed Completion Date: Corrective actions for Finding 2024-001, 2024-002, 2024-003, and 2024-004 also apply to State award findings. Finding: 2024-005 Name of contact person: Lindsey Cearlock Corrective Action: Proposed Completion Date: Immediately. To review all grant documentation carefully and ensure the County is compliant with all requirements. Section IV - State Award Findings and Questioned Costs Jessica Wall, Director YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 50 cases to verify that appropriate requests for informaiton are made. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recertifications that would ensure that appropriate information requests have been made and evaluated. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of information requests. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 50 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24. Supervisors will provide staff with a report at least once per month that includes terminated SSI cases that require a full eligibility evaluation. Staff will return this report each month with their initials to indicate that they have initiated full evaluations. Training will be provided by 11/30/24. Training will be provided by 11/30/24 and staff will received SSI Termination Report by 11/30/24. Jessica Wall, Director
Finding 516217 (2024-002)
Significant Deficiency 2024
Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award ...
Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs Jessica Wall, Director YCHSA will inititate income calculation quizzes for staff following training to ensure understanding of training around this finding. YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 50 cases to verify appropriate income calculations and household members. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recerts that would ensure that determinations in the case and correct outcomes. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate information entry. Calculation quizzes will be in use by November 30, 2024. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 50 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24. Jessica Wall, Director YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 15 cases to verify appropriate resource entry. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recertifications that would ensure that appropriate resources have been entered and evaluated. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate resource entry. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 15 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24.
Finding 516216 (2024-001)
Significant Deficiency 2024
Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award ...
Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs Jessica Wall, Director YCHSA will inititate income calculation quizzes for staff following training to ensure understanding of training around this finding. YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 50 cases to verify appropriate income calculations and household members. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recerts that would ensure that determinations in the case and correct outcomes. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate information entry. Calculation quizzes will be in use by November 30, 2024. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 50 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24. Jessica Wall, Director YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 15 cases to verify appropriate resource entry. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recertifications that would ensure that appropriate resources have been entered and evaluated. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate resource entry. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 15 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24.
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