Corrective Action Plans

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Finding 1542 (2022-011)
Significant Deficiency 2022
The Department will establish policies and procedures to ensure first-tier subawards of $30,000 or more are reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Policies and procedures will ensure the reporting is reviewed and approved by an independ...
The Department will establish policies and procedures to ensure first-tier subawards of $30,000 or more are reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Policies and procedures will ensure the reporting is reviewed and approved by an independent person who is knowledgeable about the program. This independent review will be documented by the reviewer’s signature or initials and date of review prior to submission. The Department plans to begin this process in October 2023.
Management's Action Plan: Kevin Holland, Vice-President-Stone County and Operations will oversee the supervisory review and approval of timesheets for the next few pay cycles to ensure management is reviewing 100% of the records. He will also work to ensure none of them are being missed through spec...
Management's Action Plan: Kevin Holland, Vice-President-Stone County and Operations will oversee the supervisory review and approval of timesheets for the next few pay cycles to ensure management is reviewing 100% of the records. He will also work to ensure none of them are being missed through special circumstances as has happended in the past in order to achieve and sustain 100% compliance. Name of Person Responsible for the Plan: Kevin Holland, Vice-President Stone County & Operations. Anticipated Completion Date of the Plan: 3 payroll cycles spanning six weeks. Approximately mid-December 2023 for completion.
Grantee Response and Corrective Action Plan: We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, the Accounting Manager, Grants Manager, and Grants Supervisor attended the 2023 Southern Grants Forum in Nashville, TN. This in...
Grantee Response and Corrective Action Plan: We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, the Accounting Manager, Grants Manager, and Grants Supervisor attended the 2023 Southern Grants Forum in Nashville, TN. This investment in training assisted these key employees in understanding and implementing procedures to effectively match Federal Grant awards. We have updated our Policy and Procedures Manual to reflect a new policy of matching Federal Grant awards with non-federal funding. The Grants Supervisor reviews all invoices submitted by the Grants Manager to ensure compliance with this new policy.
Grantee Response and Corrective Action Plan: We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, a new policy was implemented that requires employees to record their time as a percentage across all grants in which they work....
Grantee Response and Corrective Action Plan: We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, a new policy was implemented that requires employees to record their time as a percentage across all grants in which they work. The employee records this allocation at least weekly within a time keeping software system. Employees and supervisors are now required to review and acknowledge payroll allocations across grants by signing weekly timesheets. Timesheets will be retained and used as backup by the Grants Department when invoicing the Grantor for expense reimbursement. In addition, we have updated our Policy and Procedures Manual to reflect this policy.
Finding 1126 (2022-001)
Significant Deficiency 2022
Information on Federal Program(s) - Department of Health and Human Services, Assistance Listing Number 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan Rural Distribution, Schedule of Expenditures of Federal Awards Reporting Periods 2 and 3, Agency Fiscal Year-Ended June 30, 2022. M...
Information on Federal Program(s) - Department of Health and Human Services, Assistance Listing Number 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan Rural Distribution, Schedule of Expenditures of Federal Awards Reporting Periods 2 and 3, Agency Fiscal Year-Ended June 30, 2022. Management’s Corrective Action Plan In response to the deficiency identified, the Agency will modify its existing internal control protocols in the following ways: • Develop emergency internal control protocols to be implemented during emergency situations whereby all items recoded by accounting staff are reviewed and signed off by the Controller or Director of Finance to ensure appropriate treatment. Train all accounting staff on this expectation. • Ensure adherence of record retention policies and procedures which are consistent with regulatory requirements. • Modify its petty cash protocols to include the review and adequate documentation of all receipts to verify allowability prior to reimbursement. Train all petty cash reviewers on this expectation. Individual Responsible for Corrective Action Plan Auston Johnson Controller 215-386-3838 Anticipated Completion Date: October 31, 2023
BA has worked with Accountant to ensure all employees complete Time and Effort sheets. These requirements have been reviewed with Building Administrators and all federally paid employees will sign the certifications. BA will review to ensure all employees have completed and will report any missing s...
BA has worked with Accountant to ensure all employees complete Time and Effort sheets. These requirements have been reviewed with Building Administrators and all federally paid employees will sign the certifications. BA will review to ensure all employees have completed and will report any missing signatures with employee’s supervisors.
View Audit 1892 Questioned Costs: $1
2022-006- Internal Control Over Compliance and Compliance - Reporting Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: April 2024 Management’s Corrective Action Plan: NGA has developed a grant reporting procedure to document all the requ...
2022-006- Internal Control Over Compliance and Compliance - Reporting Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: April 2024 Management’s Corrective Action Plan: NGA has developed a grant reporting procedure to document all the required steps including retention of support documents. This policy was finalized in August 2023 and the NGA grants management team plans to roll out and implement this process with all internal stakeholders responsible for the management of federal funds. We will continue to socialize the importance of accurate and timely grant reporting including ensuring that all federal grant reimbursements are reported following applicable federal contracts.
2022-005- Internal Control Over Compliance and Compliance – Cash Management Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: June 2024 Management’s Corrective Action Plan:NGA has developed procedures to capture all required documentation...
2022-005- Internal Control Over Compliance and Compliance – Cash Management Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: June 2024 Management’s Corrective Action Plan:NGA has developed procedures to capture all required documentation during the federal disbursement request process. Staff were informed in January 2023 of the requirements for federal drawdown documentation and the CFO proceeded with a desk audit of compliance for the first and second quarter of fiscal year 2023 in April 2023. The CFO will continue to monitor compliance and adequate document retention in the second half of the fiscal year and provide training to staff when documents are not available in shared drive folders. We will also implement a regular review of the SEFA beginning in September 2023 and use that review to ensure that revenue and cash transactions correspond to the expense reports they were based on.
2022-004- Internal Control Over Compliance and Compliance – Activities Allowed or Unallowed and Allowable Costs/ Cost Principles Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: Done. Management’s Corrective Action Plan: Since August 2022...
2022-004- Internal Control Over Compliance and Compliance – Activities Allowed or Unallowed and Allowable Costs/ Cost Principles Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: Done. Management’s Corrective Action Plan: Since August 2022, in response to technical issues with an import file that caused some timesheet allocations to not be correctly coded, the CFO has added a layer of review for payroll entries to match import file values to approved timesheets. NGA accounting team members began to train and reach out to employees to reinforce the importance of completing timesheets accurately and promptly following NGA employee policies. NGA accounting since February 2023, has completed the indirect cost, compensated absences, and fringe calculations as a part of the same process for uploading payroll entries. This ensures that the calculations are accurately calculated based on the payroll file. This has ensured that these entries are produced each payroll period and correspond to supervisor-approved timesheets under 2 CFR 200.430 Compensation – Personal Services.
• Invoices received by NYSSA pertaining to Federal Grants will be given a supervisory designee for review (current procedure) and logged on a spreadsheet prior to being delivered to the Finance Office for processing. [New procedure implemented] • Invoices to be paid will be entered into Quickbooks f...
• Invoices received by NYSSA pertaining to Federal Grants will be given a supervisory designee for review (current procedure) and logged on a spreadsheet prior to being delivered to the Finance Office for processing. [New procedure implemented] • Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager (current procedure). • Checks for payment to grant vendors follow the same procedures and processes as listed
Recommendation: See finding 2022-001. The recommendations noted for achieving appropriate oversight in the finance department apply as key individuals with knowledge of the compliance are considered critical for developing an appropriate control environment for internal controls over compliance. Pl...
Recommendation: See finding 2022-001. The recommendations noted for achieving appropriate oversight in the finance department apply as key individuals with knowledge of the compliance are considered critical for developing an appropriate control environment for internal controls over compliance. Planned Corrective Action: We agree with the recommendation. Since year end the Agency has hired a COO, and CFO to fill vacancies within the Agency. Under this new leadership structure, the Agency will continue to work on establishing appropriate controls.
Finding 409 (2022-005)
Material Weakness 2022
Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: During testing, there were two debt covenants, net worth and the amount of capital expenditures, that w...
Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: During testing, there were two debt covenants, net worth and the amount of capital expenditures, that were not included in the monthly covenant report included in the financial packet for monitoring. There was also no control in place to seek approval prior to reaching the capital expenditure threshold of $100,000. Responsible Individuals: Nathan Johnson, CEO and Dan Stone, CFO Corrective Action Plan: We will update our monthly covenant report to include the net worth calculation and the amount of capital expenditures. We will actively seek lender approval prior to exceeding capital expenditures over $100,000. Anticipated Completion Date: December 31, 2023
Finding 408 (2022-004)
Significant Deficiency 2022
Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no formal documented review over the reserve fund reconciliation for the federal program. Re...
Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no formal documented review over the reserve fund reconciliation for the federal program. Responsible Individuals: Nathan Johnson, CEO and Dan Stone, CFO Corrective Action Plan: We have adopted a policy to enhance internal control to ensure the reserve fund reconciliation has a secondary review and approval that is documented. Anticipated Completion Date: August 31, 2023
Finding 406 (2022-003)
Material Weakness 2022
Federal Agency Name: U.S. Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Financial...
Federal Agency Name: U.S. Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Financial Assistance Listing #93.498 Finding Summary: Eide Bailly LLP prepared our consolidated schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Responsible Individuals: Nathan Johnson, CEO Corrective Action Plan: Having auditors assist with preparing the consolidated schedule of expenditures of federal awards (Schedule) is not unusual. We will continue to be aware of the financial reporting requirements relating to PioneerCare’s consolidated schedule of expenditures of federal awards and internal control that impact financial reporting. Anticipated Completion Date: Ongoing
Finding 304 (2022-002)
Significant Deficiency 2022
Condition Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determi...
Condition Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determine the reports were materially accurate; however, no evidence of a formal supervisory review and approval of the reconciliation was maintained on-file in these three instances. Correction action As of Q4 2022, the Atlanta-based Co-CEO and the Chief of Programs and Administration have instituted a process of review and approval of drawdown reconciliations prior to drawdown to review for accuracy of calculations and to ensure that previous drawdown amounts are accurately recorded. A Finance Manager was hired in April 2023, and the responsibility of ongoing drawdown reconciliation and calculation of invoice amounts has shifted to the Finance Manager position. Monthly invoices and drawdowns are being reviewed and approved by the Co-CEO and Chief of Programs and Administration prior to drawdown. Responsible Person Co-CEO and Chief of Programs and Administration Anticipated completion date Completed - This process is currently in place.
Finding 303 (2022-001)
Significant Deficiency 2022
Condition We reviewed all subawards made by the grantee during the audit period and found that 4 of them, totaling $224,000, were not reported to the FSRS. Correction action The FSRS will be submitted to the FFATA website. Responsible Person The Chief of Programs and Administration will submit the F...
Condition We reviewed all subawards made by the grantee during the audit period and found that 4 of them, totaling $224,000, were not reported to the FSRS. Correction action The FSRS will be submitted to the FFATA website. Responsible Person The Chief of Programs and Administration will submit the FSRS under the supervision of the Co-CEO. Anticipated completion date Within 30 days
The County is in the final stages of implementing grant policies, which will cover reimbursement procedures for all departmental grants. The County will work with the pass-through grantor to repay the amounts the County received in excess. The County will work with the Health Department director a...
The County is in the final stages of implementing grant policies, which will cover reimbursement procedures for all departmental grants. The County will work with the pass-through grantor to repay the amounts the County received in excess. The County will work with the Health Department director and staff to review grant policies and procedures.
View Audit 240 Questioned Costs: $1
To assist the County, meet the WIOA 75% earmarking requirement for out-of-school youth program, the County will develop written policies and procedures for its WIOA Youth Activities program. The County will provide eligible out-of-school youth the opportunity of paid work experiences (WEX). The Co...
To assist the County, meet the WIOA 75% earmarking requirement for out-of-school youth program, the County will develop written policies and procedures for its WIOA Youth Activities program. The County will provide eligible out-of-school youth the opportunity of paid work experiences (WEX). The County will also work with the pass-through grantor to develop an effective strategy to recruit and retain eligible out-of-school youth. The County will monitor the out-of-school services spending throughout the fiscal year and award period.
View Audit 240 Questioned Costs: $1
CORRECTIVE ACTION PLAN FINDING 2021-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities-Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Programs: Water and Waste Disposal Systems for Rural Communities Contact Person Responsible for Corrective A...
CORRECTIVE ACTION PLAN FINDING 2021-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities-Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Programs: Water and Waste Disposal Systems for Rural Communities Contact Person Responsible for Corrective Action: Bart Whitesitt-Clerk- Treasurer Contact Phone Number and Email Address: Office: 765-345-5977 Cell: 317-508-7297 Email: bwhitesitt@townofknightstown.in.gov Views of Responsible Officials: We concur with the findings from IN State Board of Accounts entitled: “Internal Control Over Suspension and Debarment Compliance”. We also definitely agree that the Town needs corrective action to prevent using funding from Federal or State grants to pay vendors that have a suspended or debarred status. The Town needs to adopt policies and systems that will strengthen “Material Weakness” and mitigate any “Material Noncompliance”. Description of Corrective Action Plan: Section III Finding: Internal Controls were not followed, concerning the Suspension and Debarment Compliance of the Town utilizing funds from the Rural Communities Grant to pay 3 various vendors who were on the suspended or debarred status list. To prohibit this from happening in the future, I would propose 2 strategies for the Corrective Action Plan. 1. The Town needs to utilize their Engineering Firm, which currently happens to be HWC. In the past, the Engineer has done research on grants and other sources of funding for the Town. The Town should require the Town Engineer to research and keep an updated list of vendors not to use that have a suspended or debarred status. Collecting certification from the vendors the Town use verifying they do not have a suspended or debarred status could also be done by the Town Engineer HWC. 2. The 2nd protocol or policy for the Town to initiate to mitigate using any vendors that have a debarred or suspended status, especially for any projects utilizing any funds from State or Federal Grants, would be for the Town to implement a more advanced approval chain of command process. A more advanced approval chain of command process is already starting to evolve. On or around May 4, 2026, the Town Office is going to “Go Live” and initiate their new Accounting Software program with Boyce Systems. This new program will have a much more advanced and structured approval chain of command processes. The Billing Clerk will initiate the process of approving a batch of APV Vouchers to be approved and checks to be cut to vendors. The Billing Clerk is the first person in the tier of the approval process of bills. With the new software system, the Clerk- Treasurer approves the Deputy-Clerk-Treasurer and the Billing Clerk on the APV checks to the various vendors. Therefore, with the new Boyce Software system the Town is going to there will be 2 more individuals in the approval process that will help mitigate any mistaken invoices or checks to vendors that have a suspended or debarred status. Anticipated Completion Date: 1. The Town has already recently hired a new Engineering Firm HWC. Therefore, I am going to immediately email a request for the Town Engineer HWC to “Red-Flag” the Town not to use any vendors and especially not to pay any vendors with State or Federal Grant funds that have a suspended or debarred status. The Town Engineer HWC will need to keep an updated list that will be ongoing. Collecting certification from the vendor verifying they do not have a suspended or debarred status will ultimately need to be done by the Town Manager, Town Council members, the Town Engineer HWC, the Town Office staff, and the Clerk-Treasurer. Whoever seeks out the vendor will oversee making sure they do not have a suspended or debarred status, very similar to the solicitation of the W-9 of contractors the Town uses. This Corrective Action Plan should take place immediately. 2. The 2nd Corrective Action Plan will take place on or around Approximately May 4, 2026, when the Town Office gets our new Software system. Very simply, having multiple individuals involved in the approval process of Invoices and the distribution of funds to various vendors will greatly behoove the Town’s oversight process. Respectfully Submitted by Clerk-Treasurer Bart Whitesitt INDIANA STATE
Finding Reference Number: SA2021-001 - Internal Control Assistance Listing Number: 14.850 and 14.872 Assistance Listing Title: Public and Indian Housing and Public Housing Capital Fund Name of Federal Agency: Department of Housing and Urban Development Contact Person: Antoinette Terrell, Executive D...
Finding Reference Number: SA2021-001 - Internal Control Assistance Listing Number: 14.850 and 14.872 Assistance Listing Title: Public and Indian Housing and Public Housing Capital Fund Name of Federal Agency: Department of Housing and Urban Development Contact Person: Antoinette Terrell, Executive Director & Rita Martinez, Finance Manager II Corrective Action Plan: The City has assigned staff to specific duties to support the Authority’s financial operations. Staff have implemented new processes that align with the City’s policies and procedures, while also in accordance with HUD regulations and requirements, to improve the integrity and accuracy of the Authority’s financial reporting and management of federal awards. The procedures ensure separation of duties and levels of approval to handle and manage federal funds. Staff also continue to attend trainings to understand Federal statutes and regulations. Completion Date: July 1, 2022
Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend the Organization develop a system of i...
Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend the Organization develop a system of internal controls to ensure that salaries and related payroll expenses are tracked to reasonably reflect the actual time spent working on the programs. In addition we recommend that management retain all documents including evidence of review and approval for all expenditures of federal funds until the latter of the legally required retention period or completion of required audits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented internal control procedures to strengthen payroll allocation practices and documentation retention for federally funded expenditures. The Organization has established a process to ensure that salaries and payroll-related costs charged to federal programs are supported by appropriate time tracking and allocation documentation that reasonably reflects actual time worked on each program. Supervisory review and approval requirements have been implemented to validate payroll allocations and supporting documentation. Additionally, the Organization has reinforced documentation retention standards by requiring retention of all federal expenditure support, including invoices, approvals, reconciliations, and evidence of review, in accordance with federal retention requirements and audit availability standards. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026
Department of Veterans Affairs Federal Program Name: VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to ensure that required reports are accurate and subm...
Department of Veterans Affairs Federal Program Name: VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 64.024 Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to ensure that required reports are accurate and submitted within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented formal reporting controls to ensure all required reports are prepared accurately, reviewed appropriately, and submitted within the required timelines. These controls include a structured reporting calendar with submission deadlines, assignment of responsibility for report preparation and review, and a standardized review and approval process prior to submission. The Organization has also developed documentation procedures to retain evidence of supervisory review, validation of key data points, and confirmation of timely submission. These enhancements are intended to reduce risk of late submissions and improve the accuracy and consistency of program reporting. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026
The BOCC will be more diligent in their overview of grant applications to ensure that all federal grant application requests are not reimbursable through any other federal grant program. All transactions regarding federal grants will be required to be flagged with the grant information and will requ...
The BOCC will be more diligent in their overview of grant applications to ensure that all federal grant application requests are not reimbursable through any other federal grant program. All transactions regarding federal grants will be required to be flagged with the grant information and will require approval by the BOCC before any action can be taken. BOCC will determine the validity of each transaction to ensure compliance with grant requirements.
The BOCC will develop internal control procedures to help ensure that federal grant funding is monitored more closely and that expenditures are verified to be in compliance with grant requirements. Future grant recipients will be required to have BOCC approval before expenditures can be turned in fo...
The BOCC will develop internal control procedures to help ensure that federal grant funding is monitored more closely and that expenditures are verified to be in compliance with grant requirements. Future grant recipients will be required to have BOCC approval before expenditures can be turned in for payment. Grant recipients will also be required to have BOCC approval before depositing grant funds. This should ensure that all transactions are in compliance with grant requirements.
Finding 1167055 (2021-009)
Material Weakness 2021
Finding 2021-008 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding 2021-009 Noncompliance with Eligibility Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to supp...
Finding 2021-008 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding 2021-009 Noncompliance with Eligibility Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to support compliance with each requirement. 37 • Implementing periodic reviews of documentation completeness before charging costs to federal awards. • Providing training to staff responsible for grant management on compliance and record retention requirements. • Retain all documentation related to federal awards in a central location. Management agrees with the finding and the recommendation. During the audit period in the following years until present STOP’s clear policy and practice was to only provide service to individuals and families whose annual income does not exceed the established threshold on the federal poverty guidelines as published annually. While documentation was deficient to demonstrate eligibility for a small number of the total files sampled, the missing documentation is not an indicator that ineligible applicants received services. To address the root causes, the following actions have been implemented: The Organization has implemented Bill.com Accounts Payable workflow and document retention platform as noted above. All STOP staff have/will participate in annual in-service training and will be provided updated eligibility criteria annually. This ensures that all staff have proper information and adheres to the federally published poverty guidelines and that agency practices of only providing services to individuals who meet the established criteria are provided services. Additionally, all files will include an eligibility checklist outlining all documents needed to support eligibility and will also include a compliance reviewer signature. This should ensure that all files are complete and have necessary documentation to support eligibility. Completion Date: December 2025 The individual responsible for ensuring these issues are resolved is Michelle Bryant, Interim CEO. If there are questions regarding these plans, please call Michelle Bryant at 757-858-1360. Michelle Bryant, Interim CEO
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