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Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and deter...
Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023
Finding 384354 (2023-001)
Significant Deficiency 2023
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated fed...
Condition: During our testing of the 240-day requirement, we noted the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: As of January 2024, the University implemented a monthly process for the coordinated review of stale-dated checks. After the close of each month, the Accountant II and Business Analyst in the Controller’s Office prepares a report of stale-dated checks and sends the report to the Assistant Director of Student Accounts and the Student Accounts Business Analyst in University Financial Services. These staff members identify federal funds to be returned to the Department of Education. The Office of Student Accounts works with the Office of Financial Aid to ensure funds are returned. This process has addressed any backlog of checks, and the monthly process keeps the University current in processing stale-dated checks and returning funds in a timely manner. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Effective immediately.
View Audit 297469 Questioned Costs: $1
Finding 384353 (2023-002)
Significant Deficiency 2023
Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined th...
Condition: During our testing, we noted two of the Perkins files in which the MPN was not retained on file for loans with outstanding balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The University determined there are a total of 39 Perkins loans with missing MPNs. Of these, 6 loans are with 3rd party collection agencies, 19 are paid in full and 14 are in repayment. For these 39 loans, the University determined that alternative documentation such as exit counseling and repayment records has been retained. The Perkins Assignment and Liquidation Guide (p.4), ED tells schools to collect alternative documentation, explain the reason the note is missing and affirm the school has searched all records for each loan missing documentation. Due to the discontinuance of the Perkins loan program, no new MPNs will be issued. Name of the contact person responsible for corrective action: Andrew Cullen, Associate Vice Chancellor, Finance and Janet Burkhardt, Assistant Vice Chancellor, University Financial Services. Planned completion date for corrective action plan: Corrective action plan completed in August 2023.
Finding 384322 (2023-003)
Significant Deficiency 2023
Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than ...
Finding 2023-003: Cash Management The Institute had three instances of return of funds that resulted in excess cash for Federal Direct Student Loans ranging from $94 to $46,049 during the period of September 19, 2022 through November 29, 2022. In these situations, the excess cash, being less than one percent of total prior year drawdowns, were not returned within a seven day tolerance period. Corrective Action Plan A Student Bursar was hired in November 2022 and onboarding included comprehensive federal funds cash management training with an outside consultant. A review of cash management policies in place was conducted at that time and monitoring procedures and reconciliations were enhanced to eliminate excess cash. Contact Person Christine Frankhauser Controller cfrankhauser@erikson.edu Anticipated Completion Date January 2023
Finding 384321 (2023-002)
Significant Deficiency 2023
Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Reg...
Finding 2023-002: Enrollment Reporting For two out of four students tested (50%) who withdrew from the Institute, the students’ enrollment status reported to the National Student Loan Data System (NSLDS) did not match the institution’s records. Corrective Action Plan The Director of Research, Registration, & Records, who oversees the Registration & Records office has taken steps to ensure timely and accurate reporting moving forward. In summer 2023, a new full-time Registrar was hired to oversee the office. Additionally, Erikson has updated the functioning of its student information system in ways that are compatible with timely and accurate reporting. Changes to the system have been tested and implemented. Lastly, Erikson created a new Business Analyst position and is in the process of hiring to oversee administration and maintenance of the student information system in ways that will continue to facilitate timely reporting and data integrity. Contact Person Leanne Beaudoin Ryan, PhD Director of Research, Registration, & Records lbeaudoinryan@erikson.edu Anticipated Completion Date Updates to processes and procedures were completed in September 2023. Transition from outsourced staffing to the newly-created position is expected by May 2024.
The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...
The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.
The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.
The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.
2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporti...
2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.
The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits studen...
The school will continue to effectively streamline processes regarding leaves of absences and withdrawals and data entry into the Student Information System (SIS). In part, the separation dates will be manually entered with the National Student Clearinghouse (NSC). To note, the school permits students to take leave of absences (LOA) for up to two semesters, which is greater than the Federal Student Aid (FSA) allows (180 days). The Registrar’s Office codes students on leave with a separation date in our SIS, the student will also be coded as such with NSC. If the student does not return from a LOA after 180 days (6 months), the NSC student record will be updated to a withdrawn status effective one day before or one day after the leave began as recommended by NSC.
The School’s Finance and Financial Aid departments will more closely coordinate the vetting of the numbers before entering on FISAP. The two departments will schedule annual meeting to discuss and review the numbers.
The School’s Finance and Financial Aid departments will more closely coordinate the vetting of the numbers before entering on FISAP. The two departments will schedule annual meeting to discuss and review the numbers.
Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after w...
Monthly reconciliation reports resumed in a more detailed manner effective December 2022 with the arrival of the new Senior Associate Director of Financial Aid. The process was a collaborative effort between the Senior Associate Director and MSM’s Financial Aid consultant through August 2023 after which the function resides with the Senior Associate Director.
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. St...
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A representative from the Registrar’s Office will meet monthly with a representative of the Financial Aid Office to provide spot-checks and quality assurance to the student information uploaded to NSLDS. Student information is uploaded to the NSLDS monthly, so this should provide another layer of assurance each time information is submitted. An internal deadline and standing meeting will be established to ensure consistent compliance. Person Responsible for Corrective Action Plan: Joseph D. Garner III, Registrar Anticipated Date of Completion: The new process will begin April, 2024.
2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program),...
2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend that the University designate an individual to oversee the information security function and work to update the University’s written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Illinois Wesleyan University will designate an individual to be the Information Security Officer. The information security policy will be updated as applicable for GLBA standards. Name(s) of the contact person(s) responsible for corrective action: David Myron Planned completion date for corrective action plan: Updates for the information security policy will be made on an as-needed basis for applicable changes. The Information Security Officer will be named in Spring 2024. If the Department of Education has questions regarding this plan, please call Scott Seibring at (309) 556-3096.
2023-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program),...
2023-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When a graduation has been confirmed outside of the normal timeframe due to later grade reporting, the Assistant Registrar will include the Director of Financial Aid and the Associate Director of Financial Aid in an email along with the standard process of notifying the Associate Registrar. The Associate Director of Financial Aid will go directly to NSLDS and enter the graduation date in NSLDS. The Associate Registrar will continue the normal reporting process with the Clearinghouse but this will alleviate challenges that come when the Associate Registrar is resolving discrepancies and can’t report the graduation immediately. Name(s) of the contact person(s) responsible for corrective action: Scott Seibring Planned completion date for corrective action plan: This process will be implemented starting with the Spring 2024 semester.
Finding 2023-002 Significant Deficiency over Special Tests and Provisions - Enrollment Reporting The University acknowledges that there was 1 out of the 14 students selected that the change in , - 0 enrollment status was reported by the University more than 60 days after the enrollment status change...
Finding 2023-002 Significant Deficiency over Special Tests and Provisions - Enrollment Reporting The University acknowledges that there was 1 out of the 14 students selected that the change in , - 0 enrollment status was reported by the University more than 60 days after the enrollment status change. Effective with the Student Enrollment Roster received from NSLDS in 2024 the business practice has changed with the implementation of the modernized NSLDS Professional Access website. Upon receipt of the Student Enrollment Roster, the file is updated by an updated algorithm using data from the University’s CRM, Jenzabar. The resulting spreadsheet is uploaded to NSLDS for verification and submittal. The accepted records are updated in NSLDS' database and are removed from the resulting spreadsheet produced by NSLDS. The records that error-out are listed on the resulting spreadsheet. This file is maintained for audit purposes. To ensure accurate enrollment status updates, the records listed on the resulting spreadsheet are updated manually on the NSLDS website. The manual entries are updated in real-time. In addition, the University is updating enrollment status changes manually upon receipt of Action Forms initiated by the student instead of waiting for the next Enrollment Report from NSLDS. This should correct the issue where a change in student status was not captured by NSLDS and reasonably ensure compliance with Federal status. Contact Person: Kim Wittler, AVP, Enrollment and Financial Aid Completion Date: March 1, 2024
Finding 384147 (2023-003)
Significant Deficiency 2023
Corrective Action: Since all full-time students receive institutional aid, they must all have an aid package in our system in order for us to disburse that aid to their account. All new students would need to be presented with an award offer in order to make decisions about any financial responsib...
Corrective Action: Since all full-time students receive institutional aid, they must all have an aid package in our system in order for us to disburse that aid to their account. All new students would need to be presented with an award offer in order to make decisions about any financial responsibilitiy created by enrolling at Lyon College, so I believe all students received award offers. Going forward, the new (manual) digital file system will be more familiar to us and the learning curve less steep. Our normal process will include placing a copy of the award letter in every student's digital file. We will add a process to be run after the census date of each semester - as well as at later dates in the semester - to make sure that every full-time student and every student with federal aid has a digital file that includes a copy of their award offer, even those who submit a FAFSA after classes have begun for the semester. Proposed Completion Date: June 30, 2024
Finding 384146 (2023-002)
Significant Deficiency 2023
Corrective Action: The "Timely Reporting" issue resulted from a misunderstanding in the Registrar's Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office's personnel and established procedures designed to prevent it from happening i...
Corrective Action: The "Timely Reporting" issue resulted from a misunderstanding in the Registrar's Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office's personnel and established procedures designed to prevent it from happening in the future. The "Funds Not Returned Timely" reflects continued improvements resultig from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2024
deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to p...
deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will communicate with our third party servier to understand when they believe their SSAE 18 report will be issued. If it will be late, we will coordinate with them to perform the necessary testing to ensure we can perform the due diligence. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: June 30, 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit findi...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have taken all of the findings and placed it on our risk register. Each Wednesday, we have a vulnerability call with our VCISCO. Over the last year, we have reduced the number of vulnerabilities in our systems. Over the last month, we have begun to work on the items on our risk register. We have a working session set for April 8, 2024 to update all findings that relate to the policies that were not to standard. For the other items, we will work on our weekly calls to set up the necessary SOPs to address the deficiencies. Name of the contact person responsible for corrective action: Director of Computer Services of Network Jonathan Breitbarth Planned completion date for corrective action plan: June 30, 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate the students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financi...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate the students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Counselors receive a list of students with enrollment adjustments and review for required adjustments to cost of attendance and aid, including but not limited to reviewing for any required allocations for Subsidized to Unsubsidized loans. Additionally, a report is being created to run with the Census to identify reallocation adjustments due to enrollment. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: Now in place and ongoing process.
View Audit 297264 Questioned Costs: $1
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid receives a weekly report indicating the amount and type of notifications sent in the prior week to compare to the list of actual transactions in the system. This allows for a more frequent review and notification of any errors. On the IT side of the process, the notification process has been added to their checklist to check for any new server updates. Name of the contact person responsible for corrective action: Financial Aid Director, Amanda McCaughan Planned completion date for corrective action plan: Already in place and ongoing process.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Concordia University is reporting to the National Student Clearinghouse every 30 days regarding enrollment reporting and reporting to Degree Verify within 30 days from the end of a part of the term. If a student is awarded or has a petition for a late withdrawal that will be outside of the 30 days, the Registrar’s Office will manually go into the National Student Clearinghouse and update the student records to accurately reflect enrollment. The Registrar's Office has built automated reports to assist in tracking the students who fall outside of normal reporting. In addition, the Registrar’s Office has implemented a new process to catch students who have incorrect anticipated graduation dates in the system, so students are pulling more accurately on the awarding list. The Registrar’s Office, after initial reporting will be reviewing all students who are between 95%-100% program completion via Degree Works. The Registrar’s Office is researching how to clean up data within Banner to assist with accurate graduation dates. The Registrar’s Office is in constant communication with the National Student Clearinghouse regarding reporting deadlines, and the National Student Clearinghouse has provided when the data was submitted to NSLDS which is within the regulated timeframe. Name of the contact person responsible for corrective action: Registrar Lynn Lundquist Planned completion date for corrective action plan: Now in place and ongoing process
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the 2022 Corrective Action Plan submitted in March 2023, a report was built to pull all withdrawals for the semester and broken down by module enrollment. This is reviewed and processed weekly after the initial aid disbursement for the semester. Financial Aid Counselors also review an Enrollment Change report daily and notify the Assistant Director and Director of Financial Aid of possible R2T4 calculations. Additionally, the Financial Aid Office is copied on all General Petition and University Withdrawal notifications to review for possible R2T4 requirements. The Loan Specialist, Assistant Director, and Director of Financial Aid have all passed the NASFAA U R2T4 course and hold the R2T4 Credential. The Director of Financial Aid also received the R2T4 Specialist designation from NASFAA. The 14 students found to be processed past the 45 days and the 5 students to have additional funds sent back, all R2T4s were processed prior to the 2022 Audit and Corrective Action Plan was put into place. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: Now in place and ongoing process
View Audit 297264 Questioned Costs: $1
Federal Award Finding Finding 2023-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number - Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in c...
Federal Award Finding Finding 2023-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number - Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in compliance with the terms of the loan agreements related to the reserve funds. Responsible Individuals: Ron Harrington, CFO Corrective Action Plan: The CFO will create the appropriate reserve accounts, as required under the loan agreements. This item will be discussed with our contact person at USDA to ensure the hospital will be in compliance with the loan agreements and letter of conditions since the closing of the loans in 2022. Additionally, management will implement a control process to enusre the monthly deposits are made as required, until the accounts are fully funded. Anticipated Completion Date: Ongoing
Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiencies): (Continued) (d) The University did not timely submit their Title IV reconciliations for testing. The University did not routinely reconcile Title IV funds throughout the year b...
Finding 2023-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiencies): (Continued) (d) The University did not timely submit their Title IV reconciliations for testing. The University did not routinely reconcile Title IV funds throughout the year between the business and SFA offices. SFA Handbook Chapter 5 CFR 668.161 through 668.176. (e) The Fiscal Operations Report and Application to Participate (FISAP) was not tested because of corrections required by the U.S. Department of Education that are still under review. 34 CFR 674.19, 675.19, 676.19. Auditor’s Recommendation – The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – (a) The Business Office will generate credit balance invoices from Jenzabar weekly to review all credit balances and ensure refunds are issued within the required 14 days per HEA regulations. (b) Financial staff will update the COA worksheet that will be available once the Board has decided on the costs for each fiscal year. This will allow information to be readily available upon the auditor's request. (c) Management has hired a new Director of Financial Aid and has employed additional assistance to help facilitate the monthly reconciliation process. Monthly recon-ciliations will be completed and the Office of Financial Aid and the Business Office will meet monthly to review reconciliations and any possible variances. (d) The institution submitted a change request on February 14, 2024. Upon approval of the change request, the FISAP was resubmitted on February 20, 2024. Per the conversation with COD, the submission is waiting for approval and is currently being processed. Once the changes are approved, the final document will be submitted.
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