Corrective Action Plans

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Assistance Listing Number (ALN) & Program Name: 11.472 Unallied Science Program (U.S. Dept. of Commerce, NOAA) Fiscal Year: FY2025 Finding: Significant Deficiency in Cash Management Compliance Documentation NPRB has already taken significant corrective action to strengthen its cash management contro...
Assistance Listing Number (ALN) & Program Name: 11.472 Unallied Science Program (U.S. Dept. of Commerce, NOAA) Fiscal Year: FY2025 Finding: Significant Deficiency in Cash Management Compliance Documentation NPRB has already taken significant corrective action to strengthen its cash management controls. Effective October 1, 2025, NBPR transitioned its accounting, financial reporting, cash management, accounts payables, grant accounting, and all related financial operations from its former fiscal agent to direct management by NPRB staff. NPRB continues to use an external accounting firm to assist with reconciliations, and provide review and internal-control advisory support Beginning October 1, 2025, NPRB implemented procedures requiring detailed supporting documentation for each federal cash draw request. Each draw support packet identifies the specific allowable expenditures being reimbursed and provides documentation sufficient to reconcile the amount requested to the underlying expenditures and NPRB’s accounting records. Draw support packets are retained electronically in accordance with NPRB’s document-retention procedures. NPRB has also implemented periodic reconciliations between federal draw activity and the general ledger, including cumulative draw activity, as well as between cumulative federal draw activity and federal expenditures reported on the SEFA. These procedures are being incorporated into NPRB's formal financial policies and procedures, including defined approval authorities, segregation-of-duties requirements, internal-control responsibilities, and documentation and retention requirements.
Finding # 2025-002: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified certain year-end cutoff adjustments related to grant revenue and predevelopment costs. The adjustments related to timing differences identified during the year-end clos...
Finding # 2025-002: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified certain year-end cutoff adjustments related to grant revenue and predevelopment costs. The adjustments related to timing differences identified during the year-end close process, including grant revenue earned in 2025 that was recorded when cash was received in 2026 and certain 2025 predevelopment costs that were not accrued at year-end. Corrective Action: Management will strengthen year-end accrual procedures, particularly for grant revenues and housing development activities, and will include review of significant subsequent receipts and disbursements to help ensure grant revenue and housing development activities are recorded in the proper period. Anticipated Completion Date: December 2026
Finding # 2025-001: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified a land acquisition financed through a promissory note that was not recorded when the transaction occurred. The matter related to a significant noncash real estate devel...
Finding # 2025-001: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified a land acquisition financed through a promissory note that was not recorded when the transaction occurred. The matter related to a significant noncash real estate development transaction that was nonroutine and did not involve a typical cash disbursement through the normal accounts payable process. Corrective Action: Management implemented procedures to identify and evaluate significant nonroutine transactions. These include early communication with finance through regular meetings and pipeline and work-in-process updates, implemented in November 2025, and a monthly close procedure for nonrecurring transactions, implemented in August 2026. Anticipated Completion Date: November 2025 and August 2026
2025-002 [2023-002]—SF 425 Reporting CORRECTIVE ACTION PLAN Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Federal Agency: United States Department of Agriculture Federal Program Name: Food In...
2025-002 [2023-002]—SF 425 Reporting CORRECTIVE ACTION PLAN Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Federal Agency: United States Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Federal Award Identification Number and Year: 2022-70423-38069, 2021-70030-35719 Award Period: Project period: multiple; Budget period: multiple Questioned Costs: None Statement of Condition NMFMA did not have adequate controls over the SF-425 reporting timeline. For two out of two SF-425 Federal Financial Reports tested, the annual and close-out reports were submitted after the due date (90 days for annual and close-out reports). Also, the annual report seems to have some clerical errors and the amounts reported did not match the general ledger for the period reported, due to markets payments being reconciled late. The difference is immaterial, and client will adjust in the next report. CriteriaIn accordance with 2 CFR 200.327 (Financial Reporting) and award terms requiring SF-425 is required to be submitted for the Food Insecurity Nutrition Incentive Grants program. Recipients use the SF-425 as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status. The due dates are 30 days after the end of the reporting period for quarterly reports, and 90 days after the end of the reporting period for the annual and close-out reports. Also, the reports need to be reviewed for accuracy and completeness. CauseNMFMA has not properly implemented a formal reporting calendar, responsibility matrix, or documented pre-submission tie-out/review due to staff turnover. EffectNoncompliance with reporting requirements; risk of USDA sanctions; risk that SEFA and drawdown monitoring rely on inaccurate data. RecommendationEstablish an SF-425 compliance calendar with automated reminders; assign preparer and independent reviewer roles; perform a documented tie-out (SF-425 to GL, bank, and SEFA) with sign-offs before submission; NMFMA staff should improve internal controls by implementing reminders with the due dates of the reports and reviewing the accuracy of the reports before submission. View of Responsible OfficialThe Executive Director will take action to make sure USDA reports are filed on time. The ED will work with the Finance Director and other accounting staff to ensure deadlines are met. TimelineTarget implementation September 30, 2026. Staff Responsible Executive Director SIGNATURE TITLE DATE
Finding #2025-002- Material Adjustments Condition: Johnson Block and Company, Inc. proposed adjusting journal entries during the audit process. We deem these entries to be material in relation to the financial statements. Since the Village did not make these adjustments in its accounting system prio...
Finding #2025-002- Material Adjustments Condition: Johnson Block and Company, Inc. proposed adjusting journal entries during the audit process. We deem these entries to be material in relation to the financial statements. Since the Village did not make these adjustments in its accounting system prior to the audit, a material weakness exists in the Village’s internal controls. Criteria: Material adjusting journal entries not prepared by the Village before the audit are considered an internal control weakness. Cause: The Village does not have policies and procedures in place to ensure that all transactions are properly recorded on the general ledger prior to the audit. Effect: This means that the proper recording and reporting of financial information may not occur within a timely manner. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The Village will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditor. Contact Person: Katherine Drake, Village Clerk/Treasurer, 608-523-4521, clerk@blanchardvillewi.gov Anticipated Completion: December 31, 2026
Finding 1227799 (2025-004)
Material Weakness 2025
The single audit process and supporting documentation was delivered and audited in a timely manner. However, due to the federal government shutdown and other unforeseen circumstances experienced by the Town of Taos, the information was not provided by the federal clearinghouse due date. A few notabl...
The single audit process and supporting documentation was delivered and audited in a timely manner. However, due to the federal government shutdown and other unforeseen circumstances experienced by the Town of Taos, the information was not provided by the federal clearinghouse due date. A few notable financial matters for the late submission of the audit were other items overseen by the Town such as capital assets and receivables related to the water/wastewater revenue and collection issues which were both as a result of staff turnover and a lack of institutional knowledge. The Town will ensure that the next year’s audit is performed timely as a whole in order for the next year’s audit reporting package to be submitted by the federal clearinghouse due date. Responsible Party: Grant Administrator, Finance Director and Deputy Finance Director Timeline: June 30, 2026
Program Federal Financial Assistance Listing Number.: 21.027 / 14.239 Federal Grantor: U.S. Department of the Treasury / U.S. Department of Housing and Urban Development Award Number and Year: Affects all grant awards included under assistance listing 14.239 and 21.027 on the Schedule of Expenditure...
Program Federal Financial Assistance Listing Number.: 21.027 / 14.239 Federal Grantor: U.S. Department of the Treasury / U.S. Department of Housing and Urban Development Award Number and Year: Affects all grant awards included under assistance listing 14.239 and 21.027 on the Schedule of Expenditures of Federal Awards. Compliance Requirement: Other – Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal awards Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The finance staff and program manager did not fully understand the distinctions between subrecipient and beneficiary, resulting in inaccurate reporting of these amounts. The City Manager and relevant department managers met to address this issue and recommend that staff undergo appropriate training. The training schedule will be discussed further, taking into consideration availability, location, and budget constraints. This was corrected in the Single Audit Report which will be filed with the Federal Government. Name of Responsible Person: Finance Leadership and Grant Program Managers Projected Implementation Date: August 1, 2026
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: The Cooperative does not have an internal control system designed to provide for a complete and ...
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: The Cooperative does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards (the schedule) being audited. We requested our auditors to assist with the preparation of the schedule and the accompanying notes to the schedule. Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the schedule of federal expenditures of federal awards and the accompanying notes to the schedule. We requested that our auditors, Eide Bailly, prepare the schedule and accompanying notes. We have designated a member of management to review the drafted schedule and accompanying notes to the schedule. Responsible Individuals: Jeremy Richert ,Chief Executive Officer and Kelly Gibbs, Chief Financial Officer. Anticipated Completion Date: Ongoing
AUDIT FINDING REFERENCE NUMBER: 2025-003 FEDERAL AGENCY: Department of Education FEDERAL PROGRAM: Student Financial Assistance Cluster - NSLDS reporting AWARD YEAR: 2024-2025 CONDITION: {REFER TO AUDIT REPORT EXPLANATION) CORRECTIVE ACTION PLAN: The College experienced turnover and process change in...
AUDIT FINDING REFERENCE NUMBER: 2025-003 FEDERAL AGENCY: Department of Education FEDERAL PROGRAM: Student Financial Assistance Cluster - NSLDS reporting AWARD YEAR: 2024-2025 CONDITION: {REFER TO AUDIT REPORT EXPLANATION) CORRECTIVE ACTION PLAN: The College experienced turnover and process change in the Registrar area during the audited year. The Registrar's office has formalized processes and enhanced communication with other departments since the year in question. The procedures currently being followed should prevent enrollment status change reporting from being out of compliance. ANTICIPATED COMPLETION DATE: Immediately CONTACT PERSON: Aimee Murch MurchA@villa.edu
AUDIT FINDING REFERENCE NUMBER: 2025-002 FEDERAL AGENCY: Department of Education FEDERAL PROGRAM: Student Financial Assistance Cluster - Gramm Leach Bliley Act AWARD YEAR: 2024-2025 CONDITION: {REFER TO AUDIT REPORT EXPLANATION) CORRECTIVE ACTION PLAN: The College has identified the reasons for its ...
AUDIT FINDING REFERENCE NUMBER: 2025-002 FEDERAL AGENCY: Department of Education FEDERAL PROGRAM: Student Financial Assistance Cluster - Gramm Leach Bliley Act AWARD YEAR: 2024-2025 CONDITION: {REFER TO AUDIT REPORT EXPLANATION) CORRECTIVE ACTION PLAN: The College has identified the reasons for its shortcomings in compliance with GLBA and is investing in IT services and infrastructure that ensures compliance for current and future years. We are already underway with moving to meet these requirements. ANTICIPATED COMPLETION DATE: Fall 2026 CONTACT PERSON: Brian Emerson bemerson@villa.edu
Effective June 2025, the Organization hired a Director of Finance to strengthen financial management, enhance internal controls, and improve oversight of financial reporting and federal grant compliance. Management has implemented enhanced grant reconciliation procedures, documented management revie...
Effective June 2025, the Organization hired a Director of Finance to strengthen financial management, enhance internal controls, and improve oversight of financial reporting and federal grant compliance. Management has implemented enhanced grant reconciliation procedures, documented management review of reimbursement requests, and standardized reporting processes to improve the accuracy and completeness of grant reporting.
Effective June 2025, the Organization hired a Director of Finance to strengthen financial management, enhance internal controls, and improve oversight of financial reporting and federal grant compliance. Management has implemented revised payroll allocation procedures, enhanced review of employee ti...
Effective June 2025, the Organization hired a Director of Finance to strengthen financial management, enhance internal controls, and improve oversight of financial reporting and federal grant compliance. Management has implemented revised payroll allocation procedures, enhanced review of employee time and effort documentation, monthly reconciliation of payroll allocations to approved timesheets before reimbursement requests are submitted, and additional management review procedures to ensure compliance with Uniform Guidance requirements.
Audit Finding Reference: 2025-002 Improve Controls Over Reporting Planned Corrective Action: Director of Operations & Impact created an 18-month reporting deliverables schedule and is reviewed quarterly on 9/22/25. The schedule of reporting deliverables has been added to a dedicated calendar in Shar...
Audit Finding Reference: 2025-002 Improve Controls Over Reporting Planned Corrective Action: Director of Operations & Impact created an 18-month reporting deliverables schedule and is reviewed quarterly on 9/22/25. The schedule of reporting deliverables has been added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications are integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact
Finding 2025-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minut...
Finding 2025-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minute issues with reporting compliance. Proposed Completion Date: This finding and corrective action plan have been reached near the end of FY26, the calendar will be implemented by December 31st, 2026 but we anticipate a similar finding for FY26.
Finding 2025-004 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minut...
Finding 2025-004 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minute issues with reporting compliance. Proposed Completion Date: This finding and corrective action plan have been reached near the end of FY26, the calendar will be implemented by December 31st, 2026 but we anticipate a similar finding for FY26.
Finding 1227711 (2025-002)
Material Weakness 2025
Adjoin
CA
2. Current Year Findings 2025-002 e. Program Name: Supportive Services for Veterans Families: CFDA 64.033 f. Criteria: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements related to timeliness of submitting...
2. Current Year Findings 2025-002 e. Program Name: Supportive Services for Veterans Families: CFDA 64.033 f. Criteria: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements related to timeliness of submitting reports to funding agencies. g. Condition: During our audit, JGD noted that there was 1 out of 5 reports submitted outside of defined due dates. The delayed reporting, if uncorrected, might result in delays in the review and approval process on claim reimbursement and ability to make informed decisions about the future requirements on grant funding. h. Response: Management acknowledges the finding. During the audit period, staffing transitions within the accounting department affected the timing of the monthly financial close process, which contributed to one required report being submitted after the established deadline. To address this matter, the organization has filled the Accounting Manager position and added a Senior Accountant to strengthen the overall accounting capacity and improve the timeliness of financial reporting. Management has also established a targeted 20-day monthly close process and enhanced monitoring of reporting deadlines to support timely submission of grant reports and continued compliance with funding requirements.
Finding No. Corrective Action Plan 2025-002 Uniform Grant Guidance Implementation Recommendation: We recommend the County finalize the assessment of its financial management system and related internal controls over federal awards during the 2021 fiscal year. This assessment should include an evalua...
Finding No. Corrective Action Plan 2025-002 Uniform Grant Guidance Implementation Recommendation: We recommend the County finalize the assessment of its financial management system and related internal controls over federal awards during the 2021 fiscal year. This assessment should include an evaluation of existing policies and procedures to determine where additional enhancements should be made or new policies created, a plan to communicate these policies to County employees, and procedures to periodically review and update, as considered necessary. Action Planned/taken in response to the finding: Kewaunee County agrees with the finding. An assessment of all grants, requirements, and related policy and procedures is in progress and will continue to: • Evaluate existing policy and procedures for needed revisions • Document revisions to policy and procedures as necessary • Communicate any new policies to employees responsible for awards • Identify awards covered by the Uniform Guidance • Set and document a schedule for periodic review and revision Policy and procedures, as well as related documentation, are being revised as necessary to ensure compliance with the Uniform Guidance. Progress continues into 2025. The Finance Director will continue to coordinate and provide assistance and guidance to departments receiving grants subject to the Uniform Guidance. Names(s) of the contact person(s) responsible for corrective action: Paul Kunesh Planned completion date for corrective action: December 31, 2026
Finding No. Corrective Action Plan 2025-003 Review of Claim Forms and Expenditure Reconciliation Recommendation: We recommend that there is an appropriate reviewer of each grant claim and monthly reconciliation. Action planned/taken in response to the finding: Management will evaluate their current ...
Finding No. Corrective Action Plan 2025-003 Review of Claim Forms and Expenditure Reconciliation Recommendation: We recommend that there is an appropriate reviewer of each grant claim and monthly reconciliation. Action planned/taken in response to the finding: Management will evaluate their current processes and procedures during staffing transitions in fiscal year 2026 to ensure that proper review of claim forms and expenditure reconciliation. Names(s) of the contact person(s) responsible for corrective action: Paul Kunesh and Brian Johnson Planned completion date for corrective action: December 31, 2026
Views of Responsible Officials: The Finance and Executive teams are aware of the delay of the reporting package to the Federal Audit Clearinghouse within the required timeframe. As noted above, abrupt award termination and the resulting unpredictability and losses of federal funding resulted in sign...
Views of Responsible Officials: The Finance and Executive teams are aware of the delay of the reporting package to the Federal Audit Clearinghouse within the required timeframe. As noted above, abrupt award termination and the resulting unpredictability and losses of federal funding resulted in significant staff turnover, multiple revisions to—and reviews of—restricted net asset balances and significant delays. The Finance and Executive teams have corrected processes leading to these delays during FY2026 to ensure timely submission of all future Data Collection Forms to the Federal Audit Clearinghouse within the required timeframe. Anticipated Completion Date: December 31, 2025
Corrective Action Plan: The Community Development department will establish written procedures for federal performance reporting that includes a reporting calendar, assigned responsibilities, supervisory review, verification against grant and financial records, timely submission and retention of doc...
Corrective Action Plan: The Community Development department will establish written procedures for federal performance reporting that includes a reporting calendar, assigned responsibilities, supervisory review, verification against grant and financial records, timely submission and retention of documentation demonstrating federal acceptance. The written policy will be reviewed annually and updated as needed. All Community Development staff will be trained on the procedures upon implementation and when updates are made. Responsible Individual: Joseph Maiorana, Assistant Community Development Project Supervisor, Town of Riverhead, is the employee responsible for development and implementation of the procedures for the EPA grant and any other existing grants specifically assigned to him. Dawn Thomas, Town of Riverhead Community Development Director, will be the employee responsible for review and supervision to ensure that the corrective action plan is implemented by all staff and that all written policies and procedures are adhered to for all existing and future grants. Planned Date of Implementation: September 30, 2026
As new acting CTD President there will be a document / calendar created with all priority dates of required audits, etc. to be certain that all CTD officers are aware of these requirements. CTD President & Treasure will plan to complete all audits and filings in a timely manner to be finished prior ...
As new acting CTD President there will be a document / calendar created with all priority dates of required audits, etc. to be certain that all CTD officers are aware of these requirements. CTD President & Treasure will plan to complete all audits and filings in a timely manner to be finished prior to any and all deadlines.
As new acting CTD President there will be a document / calendar created with all priority dates of audits, etc. to be certain that all CTD officers are aware of these requirements. CTD President & Treasure will plan to complete all audits and filings in a timely manner to be finished prior to any an...
As new acting CTD President there will be a document / calendar created with all priority dates of audits, etc. to be certain that all CTD officers are aware of these requirements. CTD President & Treasure will plan to complete all audits and filings in a timely manner to be finished prior to any and all deadlines.
Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Eric L. Gurley, Executive Director Corrective Action Plan: Access Alaska has gained efficiencies and personnel through contracted relationships to use to implement timely reporting and filing requirements. Timelines...
Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Eric L. Gurley, Executive Director Corrective Action Plan: Access Alaska has gained efficiencies and personnel through contracted relationships to use to implement timely reporting and filing requirements. Timelines, timetables, and responsible parties are in place to ensure completion. Proposed Completion Date: September 30, 2026.
Significant Deficiency in Internal Control Over Compliance and Noncompliance Related to Reporting for the Federal Funding Accountability and Transparency Act. Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges that internal pro...
Significant Deficiency in Internal Control Over Compliance and Noncompliance Related to Reporting for the Federal Funding Accountability and Transparency Act. Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges that internal procedures and oversight were insufficient to ensure timely FFATA subaward reporting. Corrective Action: To address this deficiency, AOOS will update its subaward monitoring controls to ensure full compliance with 2 CFR Part 170. Specifically, AOOS will: • Assign dedicated responsibility to designated staff to file subaward reports in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the end of the month following subaward execution. • Implement a monthly supervisory review to verify FSRS filing submissions and archive confirmation records in the subaward files. • Retroactively submit the missing FY25 FFATA reports into FSRS. 1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org Anticipated Completion Date: September 30, 2026
1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org August 17, 2026 CORRECTIVE ACTION PLAN Finding Number 2025-001 Significant Deficiency in Cash Management Compliance Documentation Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs wi...
1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org August 17, 2026 CORRECTIVE ACTION PLAN Finding Number 2025-001 Significant Deficiency in Cash Management Compliance Documentation Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges the necessity of maintaining clear, accessible documentation linking individual federal cash draws directly to specific allowable expenditures incurred. Corrective action: To address this deficiency, AOOS, in coordination with its fiscal sponsor (Alaska SeaLife Center), will establish and formalize a standardized procedure for cash draw requests. Specifically, AOOS will: • Implement documentation for every ASAP drawdown request, which will include detailed general ledger expenditure reports, invoice registers, or transaction listings matching the exact draw amount. • Establish a dual-review process requiring formal written sign-off by both AOOS and Alaska SeaLife Center prior to executing funds transfers in ASAP. • Maintain permanent digital archives of all draw support packets and perform quarterly reconciliations between ASAP drawdowns, general ledger accounts, and SEFA reporting. Anticipated completion date: September 30, 2026
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