Corrective Action Plans

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Schools and Roads - Grants to States (Compliance) We recommend that the County establish and implement formal procedures to ensure public notices related to Title III funds are issued and documented at least 45 days prior to any obligation or expenditure. This process should include clear assignment...
Schools and Roads - Grants to States (Compliance) We recommend that the County establish and implement formal procedures to ensure public notices related to Title III funds are issued and documented at least 45 days prior to any obligation or expenditure. This process should include clear assignment of responsibilities and retention of documentation as part of grant compliance records. Management's Response: The County concurs with the findings. Responsible Individual: Allen Hisky, Clerk of the Board of Supervisors; Corrective Action Plan: The Clerk of the Board will ensure that sufficient internal controls are in place for proper notification of Public Hearings at least 45 days proper to obligation or expenditures. This process should include clear assignment of responsibilities and retention of documentation as part of grant compliance records; Anticipated Completion Date: June 30, 2026.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the fi...
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the findings; Responsible Individual: Nicole Reinert, Public Health Director; Corrective Action Plan: Administrative staff will schedule out all required report dates in the Outlook calendar at least three weeks before the due date to keep responsible parties informed of deadlines. These set reminders will ensure timely submissions. The Department Head will review the submission process to eliminate congested workflow to ensure efficiency and identify any tasks that can be automated or improved. Regular check-ins will take place to discuss the status of ongoing reports.; Anticipated Completion Date: June 30, 2026.
Schools and Roads - Grants to States (Compliance) We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Manageme...
Schools and Roads - Grants to States (Compliance) We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Management's Response: The County concurs with the findings. Responsible Individual: Allen Hisky, Clerk of the board of Supervisors; Corrective Action Plan: The Clerk of the Board will ensure that sufficient internal controls are in place for proper notification of Certification Title III Expenditures and Unobligated Funds by statutory deadline. This process should include clear assignment to responsibilities and retention of documentation as part of grant compliance records.; Anticipated Completion Date: June 30, 2026.
The County will ensure vendors are not suspended or debarred in the future.
The County will ensure vendors are not suspended or debarred in the future.
The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.
The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.
Planned Corrective: Management acknowledges the control deficiency and noncompliance related to submitting quarterly Project and Expenditure Reports to the Treasury and understands the importance of complying with these requirements for transparency and accountability. The City will provide training...
Planned Corrective: Management acknowledges the control deficiency and noncompliance related to submitting quarterly Project and Expenditure Reports to the Treasury and understands the importance of complying with these requirements for transparency and accountability. The City will provide training to staff on SLFRF reporting requirements and deadlines, implement written policies and procedures to ensure timely submission of all reports, including establishing a compliance calendar with automated reminders and maintaining a reporting log to track submission dates. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Katie Eviston, Finance Director, (937) 324-7700
Planned Corrective: Management acknowledges the deficiency related to Housing Quality Standards inspections and is committed to ensuring compliance with 24 CFR §92.504(d). The City will review and update its existing tracking systems to ensure inspection due dates for all HOME-assisted properties ar...
Planned Corrective: Management acknowledges the deficiency related to Housing Quality Standards inspections and is committed to ensuring compliance with 24 CFR §92.504(d). The City will review and update its existing tracking systems to ensure inspection due dates for all HOME-assisted properties are accurately monitored, and will confirm that responsibility for scheduling and completing inspections is clearly assigned to a designated staff member within the Community Development department. Overdue inspections will be completed promptly, with results documented in accordance with HUD requirements. In addition, the City will review and revise current policies and procedures to strengthen inspection scheduling, address staff turnover contingencies, and improve compliance monitoring. Staff will receive updated training on HUD property standards and inspection requirements to ensure ongoing compliance. Progress will be monitored quarterly, and updates will be provided to management and the governing body. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Logan Cobbs, Community Development Director, (937) 324-7381
Action Taken: The City has implemented new policies and procedures regarding grant reimbursements including, but not limited to, the creation of a grants unit. All activities regarding reimbursements are required to be reviewed and approved by a designee of the City’s CFO and other employees as iden...
Action Taken: The City has implemented new policies and procedures regarding grant reimbursements including, but not limited to, the creation of a grants unit. All activities regarding reimbursements are required to be reviewed and approved by a designee of the City’s CFO and other employees as identified. In addition, any project associated with outside funding has gone through or will go through a reconciliation process to evaluate its current standing, including all related receivables and payables, and will continue to do so monthly. The City is working to ensure all invoices are paid within a timely manner of the related award advances and according to application of Federal and State regulations.
Finding ref number: 2023-002 Finding caption: The Town did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of Town contact person: Randy Kilmer, Clerk/Treasurer PO Box 278 Twisp, WA 98856 Corrective action the auditee pl...
Finding ref number: 2023-002 Finding caption: The Town did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of Town contact person: Randy Kilmer, Clerk/Treasurer PO Box 278 Twisp, WA 98856 Corrective action the auditee plans to take in response to the finding: Town of Twisp has since been working to draft updated federal award/purchasing/reporting policy, not only to address processes for procurement, but to establish federal purchasing policy in compliance with the recommendation of the recent audit findings including discipline for non-adherence to the policy. This Policy was adopted in October of 2024 and will alleviate any further issues with Federal procurement requirements. Anticipated date to complete the corrective action: Completed
There is no disagreement with the audit finding. All federal programs will have a federal programs director/coordinator and the Business Office will work closely with the federal programs director/coordinator to ensure that all federal compliance measures are met. A calendar of all federal reporting...
There is no disagreement with the audit finding. All federal programs will have a federal programs director/coordinator and the Business Office will work closely with the federal programs director/coordinator to ensure that all federal compliance measures are met. A calendar of all federal reporting requirements will be developed and maintained. This calendar will be reviewed monthly to ensure all federal compliance timelines are met. A federal program grant activity report will be shared monthly with the district leadership team. This report will keep financial monitoring to the forefront of the leadership team. All federal program reporting will be reviewed with the Business Office prior to submission. Business Office will complete federal program management and reporting training by December 31st by working with the federal program specialists at the State Department of Education and reading and retaining for future reference any grant specific guidance.
Management is aware that significant year-end adjustments are required for accrual basis financial statement presentation and does not believe the adjustments indicate a misstatement or error in financial reporting although material in amount. Management has the skill, knowledge and experience regar...
Management is aware that significant year-end adjustments are required for accrual basis financial statement presentation and does not believe the adjustments indicate a misstatement or error in financial reporting although material in amount. Management has the skill, knowledge and experience regarding the District operations to understand and take responsibility for the adjusting journal entries. The District has also engaged an external CPA to come to the office on a monthly basis to assist with monthly reconciliations and adjustments
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. Recommendation: CLA recommends EDB update policies to match Uniform Guidance requirements and to update procedures to require document be kept showing that suspension and debarment checks are done prior to entering into a cov...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. Recommendation: CLA recommends EDB update policies to match Uniform Guidance requirements and to update procedures to require document be kept showing that suspension and debarment checks are done prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Policy Updates: Update all policies and procedures to align with Uniform Guidance requirements (2 CFR Part 200) related to suspension and debarment compliance. 2. Suspension and Debarment Checks: Implement procedures requiring that suspension and debarment checks be performed and documented prior to entering into any covered transaction. Maintain evidence of these checks in accordance with federal requirements. 3. Documentation and Records: Establish a systematic process for maintaining documentation showing that suspension and debarment checks have been completed for all covered transactions, ensuring records are readily available for audit purposes. Name(s) of the contact person(s) responsible for corrective action: Michael Catsi Planned completion date for corrective action plan: December 31, 2025. If the U.S. Department of the Treasury has questions regarding this plan, please call Michael Catsi at 253-924-9031.
Finding No. 2023-001 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action: We agree with this finding and the department will have to seek available funds from our State General Funds to settle this. Unfortunately, this was an expenditure passed two fiscal years, I ca...
Finding No. 2023-001 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action: We agree with this finding and the department will have to seek available funds from our State General Funds to settle this. Unfortunately, this was an expenditure passed two fiscal years, I can only admit that the payment process sounded acceptable due to the urgency of the situation at that time; however, now that we have realized that Sector money used to bring the students back was inappropriate and should not have been allowed, we regretfully have to admit our failure and seek solutions to settle this appropriately. In line with the findings, the department of education management is looking into this with the Kosrae State Scholarship Board and agree to formulate a new disbursement policy with Sector student scholarship awards. This new disbursement policy with sector student scholarship will have all student scholarship routed thru Kosrae Department of Education Director’s office for his or his designee for compliance. The department will also strengthen it’s internal control by verifying terms and conditions specified in the Compact grant awards before we proceed with the fund disbursement. Anticipated Completion Date: Ongoing Name of Contact Person: Mr. Tulensru Waguk Director Department of Education Email: twaguk@kosrae.doe.fm
View Audit 373101 Questioned Costs: $1
Finding 2023-006: This is for Special Education Condition 1: For 4 of the transactions total question costs $512. The supporting documentations were not provided. Conditional 2: No departmental timecards or timesheets were provided to support compensation. Condition 3. Payroll with timecards, there ...
Finding 2023-006: This is for Special Education Condition 1: For 4 of the transactions total question costs $512. The supporting documentations were not provided. Conditional 2: No departmental timecards or timesheets were provided to support compensation. Condition 3. Payroll with timecards, there were no verification performed at the departments to ensure that what is being paid are correct. Root Cause Analysis a. Condition 1: Ineffective documentation retention at treasury, exacerbated by office relocation. b. Condition 2: Ineffective retention at departmental agencies where timesheets are held. c. Conditions 3(a) and 3(c): Weak internal controls over reconciliation between departmental timesheets and treasury uniform timesheets. Treasury does not regularly obtain departmental timesheets. d. Condition 3(b): Manual timecard errors from daily stamp-based systems. Corrective Actions 1. Strengthen documentation retention controls. 2. Enhance monitoring at the departmental level or implement a uniform timekeeping system to reduce reconciliation issues. 3. Require submission of departmental timekeeping reports to treasury for secondary reconciliation. 4. Ensure explanatory documentation is retained when uniform timesheets differ from departmental records. Responsible Parties For CAP 1. Director of DOTA and Payroll division For CAP 2. Special Education Administrator and his timekeepers For CAP 3. Director of DOTA and Payroll division For CAP 4. Both Department of DOTA and Special Ed Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.
View Audit 372843 Questioned Costs: $1
Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, pro...
Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, project ownership, or other required details. Conditional 2: Four (4) assets or batches of assets that met the State’s capitalization requirements were not capitalized until corrected through audit adjustments Root Cause Analysis For both conditions there is a lack of internal control monitoring over fixed asset capitalization. Corrective Actions 1. For Condition 1, the State should obtain documentation to support capitalizable values and confirm ownership. 2. For Condition 2, all assets related to health-sector acquisitions, the State should improve coordination between the Department of Health and Human Services and the State Treasury to ensure eligible items are capitalized at requisition or purchase order stage. Responsible Parties For Corrective Action Plan 1: Director of DOTA and Procurement Officer For Corrective Action Plan 2: Director of Health and his administrative officers Director of DOTA, Certification and Procurement officer Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.
Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision...
Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision. For 11 (or 23%) of 49 personnel records tested under the Compact Sector Education and Supplemental Education grants, no documentation was available to show that the annual performance evaluation had been performed. Root Cause Analysis • For advance payments, either concurrence was not obtained, or documentation was not retained; and a lack of familiarity with specific grant conditions may have contributed to the noncompliance. • For evaluations, documentation retention controls over personnel files were inadequate. Corrective Actions • For the health grants, if advance payments are necessary, the State should (a) use general fund advances with later reimbursement; (b) establish a letter of credit; or (c) obtain prior OIA concurrence. • For the Education and Supplemental Education grants, the State should strengthen controls to ensure annual evaluations are completed and retained in personnel files. Responsible Parties For bullet point one: Director of Health and his administrative officers Director of DOTA, certification and payable section For bullet point two: Director of Education and Personnel Managers Timeline Verification of Effectiveness Conduct regular assessments to ensure the effective implementation of the aforementioned action plans.
Finding 2023-002: This finding is for Education Department Condition 1. Impact: For 3 or (5%) of 60 non-payroll transactions tested, (a) no financial records were available to substantiate allowability; or (b) the available procurement file documentation was insufficient to substantiate allowability...
Finding 2023-002: This finding is for Education Department Condition 1. Impact: For 3 or (5%) of 60 non-payroll transactions tested, (a) no financial records were available to substantiate allowability; or (b) the available procurement file documentation was insufficient to substantiate allowability, as follows: The noncompliance resulted in a total questioned cost of $604. Condition 2. For 13 or (20%) of 65 payroll transactions tested, no departmental timecards or timesheet documentation was provided to support compensation, taxes, and fringe benefits. Condition 3. Of the 49 payroll transactions tested where departmental timecards or timesheet support was provided, we identified the following: 1) For 1 employee, the uniform timesheet reported 16 hours of sick leave, while the departmental timesheet reported 80 hours of regular work. 2) For 1 employee, the uniform timesheet was not signed by all required authorized signatories. 3) For 1 employee, the uniform timesheet reported 56 regular hours, while the departmental timesheet reflected 43 regular hours; however, the employee was paid for 80 regular hours, resulting in an overpayment of approximately $76 (processed on May 2, 2023). Root Cause Analysis • For Condition 1, ineffective documentation filing and retention controls were exacerbated by the relocation of the State Treasury office during the audit period. • For Condition 2, ineffective documentation filing and retention controls existed at the departmental agency level, where timesheets or other timekeeping records were retained. • For Condition 3(a), insufficient internal controls at the departmental level failed to ensure reconciliation of departmental timesheets with uniform timesheets submitted to the State Treasury. The Treasury does not consistently receive departmental support and therefore relies on agency review and certification. • For Condition 3(b), required signatory authorization controls failed at both the departmental and treasury levels. • For Condition 3(c), existing controls failed to detect and prevent the overpayment. Corrective Actions 1) For Condition 1. Strengthen documentation filing and retention controls. 2) For Condition 2 & 3 a) Enhance monitoring controls at the departmental level or implementing a uniform timekeeping system to reduce reconciliation burdens b) Establish policies requiring submission of department timekeeping report to the State treasury to allow for secondary reconciliation c) Reinforcing the requirement that when changes are made affecting uniform timesheets but not departmental records, appropriate explanatory documentation be retained. Responsible Parties For Condition 1. • Director of DOTA/Payable Section - Strengthen documentation filing and retention controls. For Condition 2 & 3 • Director of Education/Timekeepers - Enhance monitoring controls at the departmental level or implementing a uniform timekeeping system to reduce reconciliation burdens • Director of DOTA and Payroll Section - Establish policies requiring submission of departmental timekeeping reports to the State treasury to allow for secondary reconciliation. • Director of DOTA and Payroll Section - Reinforce the requirement that when changes are made affecting uniform timesheets but not departmental records, appropriate explanatory documentation be retained. Timeline Verification of Effectiveness For condition 1, the State Treasury will perform routine inspections of the filing systems to verify compliance and address individuals who resist necessary changes. For Conditions 2 and 3, payroll will not be disbursed to any department that fails to adhere to the new action plan
View Audit 372843 Questioned Costs: $1
Grants are looked at for compliance and ensures proper spending and documentation.
Grants are looked at for compliance and ensures proper spending and documentation.
Finding Reference Number: 2023-002 Description of Finding: The Authority did not complete and submit the February 28, 2023 audited financial statements and single audit by the required deadline of November 30, 2023 or 9 months from fiscal year end. Statement of Concurrence or Nonconcurrence: Authori...
Finding Reference Number: 2023-002 Description of Finding: The Authority did not complete and submit the February 28, 2023 audited financial statements and single audit by the required deadline of November 30, 2023 or 9 months from fiscal year end. Statement of Concurrence or Nonconcurrence: Authority staff agrees the audited financial statement and single audit were significantly delayed. Corrective Action: • Development of audit timeline and “needs” list to be compiled from all staff prior to audit submittal. • Engage with auditors earlier in order to meet required reporting deadlines. • Implementation of month-end closing process rather than waiting for year-end to complete all reconciliations. • Begin contacting vendors for estimates on any potential accruals prior to the end of the fiscal year.
Finding: 2023-001: Material Weakness - Untimely Audit Submission in Accordance with 0MB Uniform Guidance Description of Finding: The Sacramento Asian-Pacific Chamber of Commerce (SacAsian) did not submit its December 31, 2023 Single Audit reporting package—including the audited financial statements,...
Finding: 2023-001: Material Weakness - Untimely Audit Submission in Accordance with 0MB Uniform Guidance Description of Finding: The Sacramento Asian-Pacific Chamber of Commerce (SacAsian) did not submit its December 31, 2023 Single Audit reporting package—including the audited financial statements, Data Collection Form, prior-year status, and Corrective Action Plan—to the Federal Audit Clearinghouse by the required deadline. Cause: The submission was delayed because the Single Audit could not be completed on time due to change in audit firm and staffing shortages. Statement of Concurrence or Nonconcurrence: SacAsian agrees with the finding. Corrective Action: SacAsian understands the seriousness of this deficiency and the need for strict adherence to timely audit submissions per the OMB Uniform Guidance. Additional staff have been hired to assist in accounting processes, including a Controller to review all accounting processes and procedures with the Director of Finance and implement best practice recommendations and stronger month-end closing procedures and schedule. The delay in performing the 2023 audit was caused by a change in auditors. Our previous auditor did not have the capacity to continue our audit engagement due to staff shortages related to COVID. A new audit firm identified and engaged. However, there were delays in beginning the audit, and staffing challenges internally with completing the audit such that deadlines were not met. Additionally, an external finance and accounting firm was hired in September 2025 to provide additional capacity and high-level support to bring our audits current by March 2026. The additional staffing, external expertise, and improved procedures will prevent untimely submissions in future years. Responsible Party: Ryan Fong, Director of Finance, 916-446-7883, rfong@sacasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfk@sacasiancc.org Projected Completion Date: March 2026
Management concurs with this finding. The delayed submission resulted from insufficient internal controls and oversight under prior leadership. The individuals previously responsible for this function are no longer with the Organization. Under current leadership, management has taken immediate steps...
Management concurs with this finding. The delayed submission resulted from insufficient internal controls and oversight under prior leadership. The individuals previously responsible for this function are no longer with the Organization. Under current leadership, management has taken immediate steps to strengthen oversight and ensure future compliance. Knowledgeable personnel are now in place and have been made fully aware of all federal reporting requirements and deadlines. Management is actively developing formalized policies and procedures governing federal reporting, including a centralized compliance calendar, documented workflows, defined roles and responsibilities, and an internal review process prior to submission. These measures will be implemented by the first quarter of 2026.
Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: CUAHSI acknowledges that incomplete documentation was available to show subrecipient-monitoring procedures were followed for FY 2023 wi...
Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: CUAHSI acknowledges that incomplete documentation was available to show subrecipient-monitoring procedures were followed for FY 2023 within the required timeframe. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI now follows a written Subrecipient Monitoring Policy that specifies the duties of the Director of Finance, Staff Accountant, and Principal Investigator. Monitoring of active subawards began in May 2023. The subaward monitoring process was updated on September 21 2023 and further refined in spring 2024. All subrecipients from FY 2020–2023 have been retroactively certified, and timely reviews were in place for awards from FY 2024 onward. Management performs a mid-year check to confirm that monitoring records are complete, adequate, and securely stored. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete
Confirm the specific reporting periods and deadlines for all DHHS grants, including ARP and CRRSA grants. Ensure semiannual SF-425 reports are submitted within the deadlines outlined in the grant agreements, and annual SF-425 reports for ARP and CRRSA grants Maintain documentation of submission date...
Confirm the specific reporting periods and deadlines for all DHHS grants, including ARP and CRRSA grants. Ensure semiannual SF-425 reports are submitted within the deadlines outlined in the grant agreements, and annual SF-425 reports for ARP and CRRSA grants Maintain documentation of submission dates and retain copies of all reports for audit and compliance purposes. Establish an internal calendar and reminder system to track future SF-425 reporting deadlines to prevent delays.
Finding 2023-004 Assistance Listings: 93.567 & 93.576 Issue: Eligibility documentation needed strengthening. Corrective Actions 1. Apricot Hard Stops – Mandatory ORR eligibility fields prevent enrollment without complete data. 2. Enhanced Case Notes – Case managers must document eligibility review a...
Finding 2023-004 Assistance Listings: 93.567 & 93.576 Issue: Eligibility documentation needed strengthening. Corrective Actions 1. Apricot Hard Stops – Mandatory ORR eligibility fields prevent enrollment without complete data. 2. Enhanced Case Notes – Case managers must document eligibility review and note interpreter use. 3. File Accountability – Physical files labeled with responsible case manager; cross-checked during audits. 4. Compliance Reviews – Compliance Coordinator conducts quarterly file audits. Responsible Official: Javid Siddiqi, Director of Immigration Services Implementation Date: Completed January 2025; quarterly monitoring ongoing.
Finding 2023-003 Assistance Listings: 93.567 & 93.576 Issue: Two reports were resubmitted after the deadline due to formatting problems. Corrective Actions 1. Clarification Provided – Original submissions were on time; errors arose from incompatible file formats. 2. Two-Step Review – Reports prepare...
Finding 2023-003 Assistance Listings: 93.567 & 93.576 Issue: Two reports were resubmitted after the deadline due to formatting problems. Corrective Actions 1. Clarification Provided – Original submissions were on time; errors arose from incompatible file formats. 2. Two-Step Review – Reports prepared by Compliance Coordinator, then sequentially reviewed by Director of Immigration Services and CEO. 3. Submission Log – Central log with due dates, submission confirmations, and file-format checks. 4. Quarterly Spot-Checks – Compliance Coordinator tests report files on recipient software. Responsible Officials: Javid Siddiqi (Director), Rachel Kornfeld (CEO) Implementation Date: Process in place since August 2023.
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