Veterans’ Health Foundation Corrective Action Plan Federal Drawdown Internal Control Finding 2025-001 Management agrees with the finding. The identified exceptions resulted from inconsistent retention of documented review evidence during a period of transition in finance personnel. While drawdown re...
Veterans’ Health Foundation Corrective Action Plan Federal Drawdown Internal Control Finding 2025-001 Management agrees with the finding. The identified exceptions resulted from inconsistent retention of documented review evidence during a period of transition in finance personnel. While drawdown requests were supported by allowable expenditures and subject to financial oversight, documentation evidencing the control was not consistently maintained for certain transactions. To strengthen internal controls over federal drawdown requests and ensure continued compliance with 2 CFR 200.303, the Veterans Health Foundation will revise and formalize its drawdown procedures as follows: 1. Federal drawdown requests will be prepared by designated finance personnel and supported by appropriate expenditure documentation. 2. The Controller will review supporting documentation and authorize all federal drawdown requests prior to submission to ensure the accuracy, allowability, and appropriateness of reimbursement requests. 3. The CEO will perform and document a monthly reconciliation review of drawdown activity and related expenditures as an additional oversight and monitoring control. 4. The Foundation will update its formal policies and procedures within 60 days to reflect the revised drawdown preparation, review, authorization, reconciliation, and documentation retention requirements. 5. The Foundation is strengthening its document storage and records retention processes to ensure supporting documentation for drawdowns and other federal award activities is consistently maintained, centrally stored, and readily accessible for audit and compliance purposes. 6. As part of the Foundation’s broader administrative modernization initiative, the Foundation is implementing a new cloud-based file storage and records management system during the current fiscal year to improve document retention, access controls, continuity of operations, and long-term compliance oversight. 7. Management has communicated the revised control procedures to finance personnel and will monitor compliance with the updated process. The Foundation believes these corrective actions adequately address the finding and strengthen internal controls over federal cash management activities and records retention. Responsible Officials: Controller and Chief Executive Officer Anticipated Completion Date: Policy updates will be completed within 60 days. All other corrective actions have been implemented effective immediately, with the new cloud-based file storage system to be implemented during the current fiscal year.