Corrective Action Plans

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FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Internal Controls Contact Person Responsible for Corrective Action: Todd Nobbe, Corporation Treasurer Contact Phone Number and Email Address: 812-934-2194, tnobbe@batesville.k12.in Views of Responsible Officials: We concur with the finding....
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Internal Controls Contact Person Responsible for Corrective Action: Todd Nobbe, Corporation Treasurer Contact Phone Number and Email Address: 812-934-2194, tnobbe@batesville.k12.in Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure free and reduced guidelines are reviewed by the Corporation Treasurer. The school corporation will establish a proper system for internal controls and develop procedures to ensure EFTs are reviewed by the Director of Operations. Anticipated Completion Date: Immediately 12/08/2025
December 29, 2025 Bay County Council on Aging, Inc. Management’s Corrective Action Plan For Fiscal Year Ended March 31, 2025 Finding Number: 2025-001 Planned Corrective Action: On March 31, 2025, the Department of Commence changed software vendors. In this system the program gives a suggested benefi...
December 29, 2025 Bay County Council on Aging, Inc. Management’s Corrective Action Plan For Fiscal Year Ended March 31, 2025 Finding Number: 2025-001 Planned Corrective Action: On March 31, 2025, the Department of Commence changed software vendors. In this system the program gives a suggested benefit amount that the household will receive. The Organization's staff member has to confirm the commitment, but the software will not allow a household to receive more than they are eligible for. Per the requirements of the new software system, the client is responsible for completing the application and uploading any required supporting documentation. The Organization is responsible for verifying the information is correct based on the supporting documentation prior to the release of the funds to the client. Anticipated Completion Date: 3/31/2025 Responsible Contact: Karen Coffman
State Agency: NYS Division of Homeland Security and Emergency Services Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) ALN #: 97.036 Single Audit Contact: Celines Jorge-Gecewicz Title: Director of Finance for Disaster Recovery Programs Telephone: (518) 473-5694 ...
State Agency: NYS Division of Homeland Security and Emergency Services Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) ALN #: 97.036 Single Audit Contact: Celines Jorge-Gecewicz Title: Director of Finance for Disaster Recovery Programs Telephone: (518) 473-5694 E-mail Address: Celines.Jorge-Gecewicz@dhses.ny.gov Audit Report Reference: 2025-012 Anticipated Completion Date: 3/31/2026 Corrective Action Planned: The Division of Homeland Security and Emergency Services (DHSES) Disaster Recovery Programs (DRP) acknowledges the identified discrepancies between amounts as reported to the Federal government and the supporting documentation associated with those award amounts as required by the Federal Funding Accountability and Transparency Act (FFATA). DHSES DRP has implemented immediate corrective actions to strengthen internal guidance related to reporting and internal controls monitoring to ensure timely and accurate FFATA reporting. The nature of FEMA reimbursement often takes years from the emergency declaration to the reimbursement of expenses and the project closeout and may include multiple disbursements to applicants over multiple fiscal years. FFATA data reported in all prior New York State Fiscal Years was completed in the now retired FFATA Subaward Reporting System (FSRS.gov). This system was retired on March 6, 2025, and replaced with subaward reporting on SAM.gov on March 8, 2025 – just 23 days before the close of State Fiscal Year (FY) 2025. All existing data from FSRS.gov was migrated to SAM.gov. During transition training, Federal representatives indicated that while there could be accuracy issues related to the data migration – grantees would not be required to remediate these issues. After the completion of migration, DHSES DRP staff noticed data inaccuracies and submitted support requests through the US General Services Administration’s Federal Service Desk (fsdsupport@gsa.gov) and USAspending Service Desk Team (usaspending.help@fiscal.treasury.gov). However, to date, no Federal solution has been identified. While efforts to identify a solution at the Federal level have been unsuccessful, DHSES DRP staff continue to review and correct all information previously submitted for open disasters. Going forward staff will make necessary corrections to SAM.gov, where feasible, to achieve full compliance. Additionally, the State will revise Budget Bulletin L-0302 - Federal Funding Accountability and Transparency Act Guidance to remind agencies to be aware of the conversion to SAM.gov and the need to verify/correct data, and report inaccuracies to the Federal government.
State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Audit Manager Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-003 An...
State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Audit Manager Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-003 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) has updated the payment procedures to require additional review prior to processing and will provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the Vocational Rehabilitation grant. Additional controls planned include the alignment of purchase orders with the Federal fiscal year to ensure cost centers are appropriately assigned to services.
State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Auditor 3 Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-002 Antici...
State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Auditor 3 Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-002 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) ACCES-VR began doing quarterly data validation reviews prior to RSA 911 submission in early 2025. ACCES-VR is also working on updating the RSA 911 Reporting Data Validation policies and procedures to address this request from the RSA monitoring visit in 2024.
State Agency: Office of Children and Family Services Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Bonnie Hahn Title: Audit Liaison Telephone: (518) 486-1034 E-mail Address: Bonnie.hahn@ocfs.ny.gov Audit Report Reference: 2025-...
State Agency: Office of Children and Family Services Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Bonnie Hahn Title: Audit Liaison Telephone: (518) 486-1034 E-mail Address: Bonnie.hahn@ocfs.ny.gov Audit Report Reference: 2025-001 Anticipated Completion Date: 3/31/2026 Corrective Action Planned: The New York State Commission for the Blind (NYSCB) opens and maintains cases of blind and visually impaired individuals who apply for vocational rehabilitation and low vision services. Participants can apply and receive services multiple times, which can result in reporting more than one cycle on the RSA-911. In some cycles, the cases were open for more than 10 years, so the original application date is reflected on the RSA-911. These instances resulted in missing signatures on applications or Individualized Plans for Employment (IPE). The NYSCB has implemented a process that requires each Senior Vocational Rehabilitation Counselor (SVRC) to select 5 cases per month to complete an internal case review. There are two Internal case review forms used- one is for the case to be reviewed at IPE development or re-development and the other form is for the case to be reviewed at placement/case closure. If the SVRC finds documentation or signatures missing, they will notify the Vocational Rehabilitation Counselor (VRC) of the missing information by providing the completed form with their comments and follow up required. This process will continue. NYSCB will be providing further training to VRCs who complete applications and develop IPEs to emphasize the importance of having the participants sign the required forms. In addition, NYSCB will be providing training to the supervisors (including SVRCs and District Managers) in each district office when applications are taken by telephone to provide reasonable accommodations to our blind participants. Senior management will develop a written protocol which each district will be required to follow for how to manage accepting applications and signatures when cases are assigned to VRCs.
Federal Agency Name: Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Corrective Action Plan: Manage...
Federal Agency Name: Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program's reserve fund is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and will sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account. Responsible Individuals: Gerry Leadbetter, Administrator Anticipated Completion Date: January 2026
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
Finding 1167181 (2025-002)
Material Weakness 2025
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
Finding 1167180 (2025-001)
Material Weakness 2025
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-002 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-001 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD...
2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documenta...
2025-002 - Missing Evidence Tenant Files Reviewed by Supervisor Corrective Action: Findings were related to required information missing from the tenant files. Corrective action has been implemented in ensuring the check list was revised to ensure all documentation is kept for each item of documentation needed to be included in the tenant files and additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing
Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Pass-Through Entity: State of Wyoming Office of State Land and Investment Board (OSLI) Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: We did not have a writt...
Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Pass-Through Entity: State of Wyoming Office of State Land and Investment Board (OSLI) Assistance Listing Number: 21.027 Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: We did not have a written procurement policy in place that aligned with all federal regulations. We also did not review vendors to ensure that they were not debarred, suspended, or otherwise excluded from participating in federal awards. Corrective Action Plan: We will review and update our procurement policy to align with all federal requirements, as well as revise our vendor policy to ensure vendors that are used for federal awards to ensure that they are not debarred, suspended, or otherwise excluded from participating in Federal awards. Responsible Individuals: Jim Cussins, CFO Anticipated Completion Date: March 31, 2026
Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Compliance Requirement: Special Tests and Provisions Finding Summary: The Center's reserve account is fully funded per the requirements of the loan resoluti...
Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Compliance Requirement: Special Tests and Provisions Finding Summary: The Center's reserve account is fully funded per the requirements of the loan resolution security agreement. However, there is no documented secondary monitoring of the reserve balance as compared to the required minimum reserve balance. Responsible Individuals: Crystal Richter, Interim CFO Corrective Action Plan: Hired an Accountant July 2025. Management will ensure there are multiple people involved and overseeing the reserve balance and documentation will be retained review and approval over the reserve balance. Anticipated Completion Date: December 2025
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