Corrective Action Plans

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Finding 2023-049 Program Information Program Name: CCDF Cluster: Child Care and Development Block Grant, COVID-19 Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund CFDA Number: 93.575/93.596 Summary of Finding Reporting Material We...
Finding 2023-049 Program Information Program Name: CCDF Cluster: Child Care and Development Block Grant, COVID-19 Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund CFDA Number: 93.575/93.596 Summary of Finding Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Agency Response Agency agrees with this finding. Corrective Action Plan This requirement has been incorporated into DSS internal controls to ensure subaward reporting is completed timely and in compliance with FFATA. Designated staff are responsible for monthly submission, documentation, and verification, with internal review procedures in place to confirm accuracy and completeness. All reports were brought current last month, and ongoing reporting is now embedded in standard operating procedures to maintain compliance. Contact Person(s) Responsible Catherine Council, Management Analyst II Phone: 775-684-0679 Email: cacouncil@dss.nv.gov Anticipated Completion Date September 30th, 2025.
Finding 2023-048 Program Information Program Name: CCDF Cluster: Child Care and Development Block Grant, COVID-19 Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund CFDA Number: 93.575/93.596 Summary of Finding Reporting Material We...
Finding 2023-048 Program Information Program Name: CCDF Cluster: Child Care and Development Block Grant, COVID-19 Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund CFDA Number: 93.575/93.596 Summary of Finding Reporting Material Weakness in Internal Control over Compliance Agency Response The agency agrees with this finding. Corrective Action Plan Procedures were implemented July 1, 2023, to validate that the fiscal amounts reported on the ACF-696 have supporting documentation in the applicable state fiscal year and additional guidance had been provided to staff on the tighter internal controls. Contact Person(s) Responsible Brook Barlow, Chief Fiscal Services Phone: 775-684-0659 Email: bebarlow@dss.nv.gov Anticipated Completion Date These procedures were implemented July 1, 2023.
Finding #2023-037 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE implement internal controls to identify required informati...
Finding #2023-037 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. NDE Response Due to rapid turnover, changes in assigned personnel, and inconsistent file architecture, NDE has struggled to ensure that source documentation is labeled and retained appropriately. Corrective Action NDE shall document standards for data and reporting, to include required standards for policies and procedures and business rules, to support the development of new and/or temporary reporting requirements in alignment with all relevant internal controls. NDE shall implement internal control monitoring specific to compliance with the data and reporting standards. The Office of Division Compliance will collaborate with the Office of Assessments, Data, and Accountability Management, as well as the Office of District Support to develop these standards. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; May 1, 2026. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.
Audit Finding 2023-031: U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Inaccurate information was reported to the federal awarding agency. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure...
Audit Finding 2023-031: U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Inaccurate information was reported to the federal awarding agency. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure Project Expenditure Reports are reconciled to underlying supporting documentation. Agency Response: Does the agency Agree with the Finding: Yes Corrective Action: The Governor’s Finance Office implemented an additional review process to ensure federal reports are accurate by reconciling amounts amongst all data sources used to compile the project expenditure reports to the federal quarterly reports. Date of Completion: Implemented effective reporting period ended June 30, 2023. Agency Contact: Lesa Galloway, ASOIV Office (775) 684-0239 lgalloway@finance.nv.gov
Audit Finding: 2023-028 Emergency Rental Assistance Program: 21.023 Special Tests and Provisions – ERA Funds Reallocation Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Supporting documentation for the application to receive reallocated funds was not mainta...
Audit Finding: 2023-028 Emergency Rental Assistance Program: 21.023 Special Tests and Provisions – ERA Funds Reallocation Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Supporting documentation for the application to receive reallocated funds was not maintained and there was not adequate segregation of duties in the preparation and review of the application. Recommendation: Enhance internal controls to ensure supporting documentation is maintained. Agency Response: The Nevada Housing Division (“Division”) does not agree with the finding. While the Division acknowledges the requirements outlined for audit in the Special Test, these do not align with the actual reallocation application which simply stated that the applicant must confirm a demonstrated need and submit monthly projections. The Division did provide these projections with its reallocation application along with households in the queue for emergency rental assistance and past monthly expenditures and households served in order to inform the projections. Corrective Action: In FY25, the Housing Division moved ERAP to the Grants Team for management, including the documentation of amounts being reported to the awarding agency. Additionally, the Division established an internal audit and compliance committee to enhance oversight of existing policies for assessing risk, monitoring, and sharing best practices across its business in January of 2024. The internal audit and compliance committee is responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Finally, the Division received legislative approval for an Auditor 3 position that will commence in October 2025 to support fiscal and overall grant compliance. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
Audit Finding: 2023-026 Emergency Rental Assistance Program: 21.023 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Key information was not reported, supporting documentation for amounts that were reported was not maintained, and there was not prop...
Audit Finding: 2023-026 Emergency Rental Assistance Program: 21.023 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Key information was not reported, supporting documentation for amounts that were reported was not maintained, and there was not proper segregation of duties relative to reporting. Recommendation: Implement internal controls to ensure reports are reviewed for accuracy prior to submission. Agency Response: The Nevada Housing Division (“Division”) agrees with the finding. The Division also acknowledges this is a prior year finding. The timing of the FY22 and FY23 state audits did not allow for any corrective actions to be reflected. Additionally, the Division would like to note, and be given consideration for, the substantive fact of the context of the time period in a pandemic, a once in a lifetime crisis that was impacting daily work and personal lives of all Nevadans, including Division staff. Finally, and importantly, the U.S. Treasury portal was a challenge to work with and guidance was often confusing and contradictory. Corrective Action: In FY25, the Division moved ERAP to the Grants Team for management of the subrecipients and reporting. Additionally, the Division established an internal audit and compliance committee to enhance oversight of existing policies for assessing risk, monitoring, and sharing best practices across its business in January of 2024. The internal audit and compliance committee is responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Finally, the Division received legislative approval for an Auditor 3 position that will commence in October 2025 to support fiscal and overall grant compliance. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
Finding 576384 (2023-025)
Significant Deficiency 2023
Audit Finding 2023-025 U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Summary of Finding: The Nevada Department ...
Audit Finding 2023-025 U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Summary of Finding: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. A VE analysis was not performed when required by NDOT policy because NDOT did not have adequate internal controls to ensure their VE policy was followed. Recommendation: NDOT should enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Agency Response Does the Agency Agree with Finding: Yes Additional Comments: Current NDOT policy has a lower cost threshold (i.e. stricter) for VE analysis than the federal requirement, and the finding references and evaluated project at that lower threshold. NDOT has also had significant organizational and staffing changes since the creation of this, and many other, policies and is currently in the process of updating all agency policies. Corrective Action Action to be Taken: NDOT will update the internal policy and processes relating to VE, including roles and responsibilities and internal controls to match or exceed federal requirements and to meet agency needs and resources. Date of Completion or Estimated Completion: October 1, 2026 Contact Person: Mark Wooster, Performance Analysis Division Head, mwooster@dot.nv.gov
Finding 576382 (2023-024)
Significant Deficiency 2023
Finding 2023-024 The minimum standards of BAM case completion were not met. The following is a summary of BAM case completion percentages that were not met: • 90- Day Completion Requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actua...
Finding 2023-024 The minimum standards of BAM case completion were not met. The following is a summary of BAM case completion percentages that were not met: • 90- Day Completion Requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actual was 84.21 %. • 120-Day Completion Requirements Paid claims require 98% completion, actual was 93.46%. Denied separation claims require 98%, actual was 92.76%. Denied non-separation claims require 98%, actual was 93.63%. Recommendation We recommend DETR enhance the internal controls to ensure BAM timeliness requirements are met. Nevada DETR's Response The Employment Security Division's Unemployment Insurance Support Services (UISS) recognizes the importance of BAM timeliness to ensure accuracy of UI benefit payments and compliance with Federal standards. Background: Timeliness issues during the review period were primarily due to workload fluctuations and staffing challenges that affected case completion rates. DETR narrowly missed the timeliness thresholds; however, no systemic issues or deficiencies in investigative procedures were identified. As noted in the U.S. Department of Labor's Annual BAM Administrative Determination Letter for Calendar Year 2023 (April 29, 2024), Nevada's BAM program was found to be in overall compliance, and no response /corrective action was required at the federal level (Attachment A). No new corrective actions were required beyond the continuation of normal BAM operations. Staff performance and workload management returned to standard levels, and DETR achieved full compliance with BAM timeliness requirements in the subsequent review period (202327-202426). DETR will continue to monitor BAM case processing to ensure that timeliness standards are consistently met. Estimated Date of Competion: COMPLETED Contact Person: Patricial Allander, ESD Deputy Administrator, DETR, ESD (775)684-3906, p-allander@detr.nv.gov
Finding 576381 (2023-023)
Significant Deficiency 2023
Finding 2023-023 Amounts reported on the ETA 9130 report did not agree to underlying financial records. A nonstatistical sample of 11 out of a population of 70 ETA 9130 reports was selected for testing. An error was noted in one of the reports tested as follows: Quarter Ended March 31, 20223 (UI3933...
Finding 2023-023 Amounts reported on the ETA 9130 report did not agree to underlying financial records. A nonstatistical sample of 11 out of a population of 70 ETA 9130 reports was selected for testing. An error was noted in one of the reports tested as follows: Quarter Ended March 31, 20223 (UI39335OB0) Amount Reported Amount Per General Ledger Federal Share of Expenditures $11,551,039 $10,567,580 Recommendation: We recommend the DETR enhance the internal controls to ensure amounts reported agreed to underlying records. Nevada DETR's Response: This was an error due to a prior staff member not interpreting data correctly from the pivot table. DETR has since changed the formatting of pivot tables to be uniform and labeled for more clarity. Attached are the updated procedure and draft internal control for all 9130 reports. Estimated Date of Completion: COMPLETED Contact Person: Zach Hoefling, Chief Financial Officer, DETR/ESD (775)684-3952 z-hoefling@detr.nv.gov
Finding Number: 2023-022 Summary of finding: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Recommendati...
Finding Number: 2023-022 Summary of finding: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Recommendation: The State agency should implement internal controls to ensure subaward information is submitted in accordance with the FFATA. CAP Response: The agency agrees and accepts this finding and will take the following steps to enhance internal controls to ensure compliance: The agency will identify appropriate staff with system access to SAM.gov to report FFATA subaward information and request access for additional staff if needed. Staff will begin reporting FFATA information on October 1, 2025. Anticipated date of completion: March 31, 2026 CAP Contacts: Cathy Balcon, Administrator, Division of Administration, Patricia Hoppe, Administrator, Division of Food and Nutrition
Responsible official: Edwin Garcia, Finance Director. Condition/Cause: Incomplete/late submission of required program reports for ALN 21.027 (SYEP). Corrective actions: (1) Created a Uniform Guidance compliance calendar for all reporting deadlines; (2) Implemented a pre‑submission peer review checkl...
Responsible official: Edwin Garcia, Finance Director. Condition/Cause: Incomplete/late submission of required program reports for ALN 21.027 (SYEP). Corrective actions: (1) Created a Uniform Guidance compliance calendar for all reporting deadlines; (2) Implemented a pre‑submission peer review checklist (accuracy, completeness, tie‑out to ledger/SEFA); (3) Standardized reporting templates mapped to the GL; (4) Automated reminders 10 and 3 days before due dates; (5) Training provided to staff on 2 CFR 200 reporting requirements and City of Chicago contract terms. Timeline: Implemented May–June 2025; sustained monitoring through December 31, 2025. Monitoring: Monthly compliance meetings with program and finance; late submissions escalated to Executive Director.
Finding Number: 2023‐003 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: Since April 2025, Federal & ...
Finding Number: 2023‐003 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: Since April 2025, Federal & State grant expenditures are verified to conform to the grant applications. Budget revisions are requested and approved before expenditures are made. After reconciling expenditures to the grant detail, timely reimbursement requests are made. Journal entries are expected to contain adequate detail and justification and Grant personnel now report to the Business Manager and Chief Financial Officer where they receive ongoing support, training and supervision. The District intends to be in compliance with 2 CFR Part 200.303 during the 2026 fiscal year.
Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The District will monitor and track federal grant...
Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The District will monitor and track federal grants expenditures and revenues in a fiscally responsible manner to reduce the number of inaccurate information.
Finding Number: 2023‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants to Local Educational Agencies 84.010 Supporting Effective Instruction State Grants 84.367 Student Support and Academic Enrichment Program 84.424 Education Stabilization Fund 84.425C Education...
Finding Number: 2023‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants to Local Educational Agencies 84.010 Supporting Effective Instruction State Grants 84.367 Student Support and Academic Enrichment Program 84.424 Education Stabilization Fund 84.425C Education Stabilization Fund 84.425D Education Stabilization Fund 84.425U Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The District will provide trainings on a regular basis for personnel responsible for grants management. The District will adhere to internal controls to ensure expenditures align to grant budgets.
View Audit 366183 Questioned Costs: $1
Finding 576299 (2023-013)
Material Weakness 2023
U.S. Department of Health and Human Services Medical Assistance Program Assistance Listing Number: 93.778 Passed Through Minnesota Department of Human Services Pass Through Number: H55215048 Award Period: 2023 Recommendation: We recommend that the County review its policies and controls to ensur...
U.S. Department of Health and Human Services Medical Assistance Program Assistance Listing Number: 93.778 Passed Through Minnesota Department of Human Services Pass Through Number: H55215048 Award Period: 2023 Recommendation: We recommend that the County review its policies and controls to ensure there is a formally documented control to ensure all reports are reviewed and the documentation of the review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will maintain a copy of the quarterly and annual cost reports that includes a written sign-off showing that the reports have been reviewed prior to the quarterly/annual deadline. Name of the contact person responsible for corrective action: Michelle Jensen, Social Services Program Operations Manager Planned completion date for corrective action plan: December 31, 2024
Finding 576297 (2023-011)
Material Weakness 2023
U.S. Department of Health and Human Services Medical Assistance Program Assistance Listing Number: 93.778 Passed Through Minnesota Department of Human Services Pass Through Number: H55215048 Award Period: 2023 Recommendation: We recommend the County implement process and procedures to provide re...
U.S. Department of Health and Human Services Medical Assistance Program Assistance Listing Number: 93.778 Passed Through Minnesota Department of Human Services Pass Through Number: H55215048 Award Period: 2023 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will continue to train staff to ensure they are aware that review of casefiles needs to be documented by a signature for all applications, all information in casefiles needs to be accurately input into MAXIS for income and assets, and all applications should be processed in a timely and accurate manner. Name of the contact person responsible for corrective action: Tiffinie Miller, Deputy Director of Employment & Economic Assistance Planned completion date for corrective action plan: December 31, 2024
Finding 576276 (2023-007)
Material Weakness 2023
U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Passed Through Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2023 Recommendation: We recommend the County implement process and procedures to pr...
U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Passed Through Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2023 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will continue to train staff to ensure they are aware that review of casefiles needs to be documented by a signature for all applications, all information in casefiles needs to be accurately input into MAXIS for income and assets, and all applications should be processed in a timely and accurate manner. Name of the contact person responsible for corrective action: Tiffinie Miller, Deputy Director of Employment & Economic Assistance Planned completion date for corrective action plan: December 31, 2024
To avoid future delays, the program will implement an internal procedure to ensure that the auditor hiring process is initiated well in advance of the fiscal year's end. This will allow us to meet the established deadlines for submitting audits to the Federal Audit Clearinghouse. During the audit p...
To avoid future delays, the program will implement an internal procedure to ensure that the auditor hiring process is initiated well in advance of the fiscal year's end. This will allow us to meet the established deadlines for submitting audits to the Federal Audit Clearinghouse. During the audit period, the program encountered challenges in securing an auditor within the required timeframe. In mid-2022, the hiring process for the FY 2021 audit was initiated, but most contacted firms were unavailable or exceeded the allocated budget. The final audit report for FY2021 was received in October 2023, at which point the program proceeded with hiring the same audit firm for FY's 2022 and 2023, as their proposal was within budget and timelines. Documentation of efforts made after October 2023 is included, along with the estimated completion date for the fy 2022 audit. These actions reflect our commitment to timely compliance and improved internal procedures to prevent future delays.
Corrective Actions Taken or Planned Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director ...
Corrective Actions Taken or Planned Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025.
Corrective Actions Taken or Planned Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel...
Corrective Actions Taken or Planned Management concurs with the finding and is currently in the process of updating the accounting system to incorporate grant-specific specific tracking codes to further align with federal reporting standards. As part of a layered approach to internal controls, Excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: November 20, 2025
Audit should be completed timely. Shoshone County Fire District No. 1 has taken steps to implement the recommendations. With the implementation of the hiring of an outside account to assist with year-end closing and provide training we will work to get back on schedule for the 9/30/2025 audit.
Audit should be completed timely. Shoshone County Fire District No. 1 has taken steps to implement the recommendations. With the implementation of the hiring of an outside account to assist with year-end closing and provide training we will work to get back on schedule for the 9/30/2025 audit.
External auditors were contracted to update the financial statements for 2023, 2024 and 2025 is in process to prepare the single audit report in a timely manner.
External auditors were contracted to update the financial statements for 2023, 2024 and 2025 is in process to prepare the single audit report in a timely manner.
Management will establish procedures to take and document a physical annual inventory and to maintain support for inventory distributions
Management will establish procedures to take and document a physical annual inventory and to maintain support for inventory distributions
The closing process will be improved to perform detailed reviews of the closing process and to obtain reliable and complete general ledger.
The closing process will be improved to perform detailed reviews of the closing process and to obtain reliable and complete general ledger.
Clean Water State Revolving Fund – ALN: 66.458 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expe...
Clean Water State Revolving Fund – ALN: 66.458 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expenditures for an audit period. Action Taken: The City of Hartwell recognizes its responsibility to prepare and present an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with Uniform Guidance. To address this finding, the City will implement formal written procedures for the preparation and review of the SEFA.
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