Corrective Action Plans

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We recommend that the Project implemenRecommendation: We recommend that the Project implement monitoring processes to ensure timely identification and deposit of residual receipts with HUD requirements and to deposit $21,073 into the residual receipts reserve
We recommend that the Project implemenRecommendation: We recommend that the Project implement monitoring processes to ensure timely identification and deposit of residual receipts with HUD requirements and to deposit $21,073 into the residual receipts reserve
Reference Number: 2025-002 Description: Special Tests and Provisions Corrective Action Plan: Guest House has implemented stronger process controls to ensure that Rent Reasonableness forms are completed prior to executing lease agreements. Staffing changes have been made to support compliance, and en...
Reference Number: 2025-002 Description: Special Tests and Provisions Corrective Action Plan: Guest House has implemented stronger process controls to ensure that Rent Reasonableness forms are completed prior to executing lease agreements. Staffing changes have been made to support compliance, and enhanced review procedures have been put in place. In addition, all previously outstanding Rent Reasonableness forms are in the process of being completed. Anticipated Corrective Action Plan Completion Date: July 1, 2026 Contact Information: For additional information regarding these corrective actions, contact Stephen Bauer, CEO at 414.345.3240. Stephen Bauer CEO Guest House of Milwaukee
Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal...
Reference Number: 2025-001 Description: Procurement Corrective Action Plan: Guest House has modified its staffing structure, training, and procurement protocols to ensure that all contractors, including local landlords receiving payments under federal grant programs, are verified against the federal System for Award Management (SAM.gov) prior to contract execution. Anticipated Corrective Action Plan Completion Date: April 1, 2026 Contact Information: For additional information regarding these corrective actions, contact Stephen Bauer, CEO at 414.345.3240. Stephen Bauer CEO Guest House of Milwaukee
2025-005: WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in...
2025-005: WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions – Wage Rate Requirements Repeat Finding: Yes. Same as finding 2024-001 and 2023-002. Criteria or Specific Requirement: Federal regulations require that contractors and subcontractors performing work on federally funded construction projects pay laborers and mechanics wages at rates not less than those prevailing on similar projects in the locality. These requirements are established under the Davis-Bacon Act and incorporated into federal grant compliance requirements under 2 CFR Part 200. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly per 29 CFR 5.5 compliance provisions. Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for one of 2 contractors that were tested and funded under the Impact Aid program, we noted that the District did not obtain or review certified payroll reports from contractors to verify compliance with federal prevailing wage requirements. As a result, the District could not demonstrate that contractors complied with required wage provisions for the sampled projects. Corrective Action: The District will ensure wage rate requirements are maintained for all vendors as appropriate under Uniform Guidance and the provision of the Davis Bacon Act. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Kay Morris, Superintendent
Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-002: The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred,...
Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-002: The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Management concurs with the finding. Arisa has subsequently received a signed certification from the subcontractor dated 4/20/2026 indicating that the vendor was not debarred, suspended, or otherwise excluded from participation in federal assistance programs. For future federal awards, Arisa will collect a certification from the subcontractor/vendor indicating compliance with this requirement. Completion date: Beginning with May 2026 invoices, certifications are required to be included.
Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-001: The Corporation failed to meet the 80% level of effort requirements as stipulated in the grant agreements. Management c...
Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-001: The Corporation failed to meet the 80% level of effort requirements as stipulated in the grant agreements. Management concurs with the finding. Arisa’s time-keeping application is designed to meet FLSA recordkeeping requirements. This system does not contain a solution to subdivide hours worked by project in a manner that would satisfy level of effort reporting. Arisa will require employees in positions that are partially or fully funded through a federal contract containing level of effort requirements to complete and submit a separate paper timesheet documenting time worked on the federal contract. In addition, subcontractors will be required to include a certification on their invoices that applicable level of effort requirements were met. Program Staff were alerted of the deficiencies in April 2026. Completion date: May 2026.
The Organization will implement an official procurement policy and set forth internal controls to follow the procedures set forth in 2 CFR Part 200 Subpart D.
The Organization will implement an official procurement policy and set forth internal controls to follow the procedures set forth in 2 CFR Part 200 Subpart D.
By expanding our internal and/or contracted accounting capacity and updating internal controls and accounting processes to include these new roles in the monthly and annual workflow, the Organization will be in better position to perform timely reconciliations and adjustments to federal grant activi...
By expanding our internal and/or contracted accounting capacity and updating internal controls and accounting processes to include these new roles in the monthly and annual workflow, the Organization will be in better position to perform timely reconciliations and adjustments to federal grant activity, ensuring timely filling of the data collection form and single audit package.
Tenant Files. 2025-001. Tenant Files Corrective action planned: The Corrective Action plan for this Audit Finding 2025-002 is that the Alexander County Housing Authority is under new management. The Housing Authority of Pulaski County was contracted on February 2, 2025, to manage this housing author...
Tenant Files. 2025-001. Tenant Files Corrective action planned: The Corrective Action plan for this Audit Finding 2025-002 is that the Alexander County Housing Authority is under new management. The Housing Authority of Pulaski County was contracted on February 2, 2025, to manage this housing authority. On this date, all HUD guidelines followed at Pulaski County were implemented at Alexander County Housing Authority. Contact person: JoAnn Pink, Executive Director. Anticipated completion date: September 30, 2026.
Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority strengthen internal controls over income determination and rent calculation by: • Enhancing procedures to ensure all sources of tenant income are properly identified, verified, and included in calculations • Pr...
Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority strengthen internal controls over income determination and rent calculation by: • Enhancing procedures to ensure all sources of tenant income are properly identified, verified, and included in calculations • Providing additional training to staff on HUD income determination and rent calculation requirements • Implementing or strengthening supervisory review controls to detect and correct errors in a timely manner Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA staff responsible for eligibility determinations will be scheduled for rent calculation training through available resources over the next FY. The PBCHA will continue to conduct internal training for program staff on eligibility documentation requirements and program rules to reinforce compliance standards. Through the implementation of intakes, interims and annual recertifications utilizing Yardi’s online workflows, the PBCHA expects to see increased improvement through automated application and documentation processes. The PBCHA will utilize available dashboards, internal audits and formal monitoring protocols to ensure continued compliance and to minimize the risk of recurring deficiencies. The PBCHA will continue to assess current staffing levels and evaluate the feasibility of restructuring, hiring outside consultants and/or increasing staffing to support consistent and compliant eligibility determinations while being cognizant of current funding uncertainties. Name(s) of the contact person(s) responsible for corrective action: Carol Jones-Gilbert Planned completion date for corrective action plan: September 30, 2027
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over HQS enforcement by implementing procedures to track and monitor HQS deficiencies and required correction timelines. Explanation of disagreement with audit f...
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over HQS enforcement by implementing procedures to track and monitor HQS deficiencies and required correction timelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA has made significant improvements in inspection compliance and will continue to monitor its third-party inspection vendor to ensure timely submission of inspection reports. The agency will utilize Yardi and other centralized tracking systems to monitor inspection due dates and follow-up activities, ensuring inspections are completed in accordance with HUD requirements. PBCHA will also provide ongoing staff training to reinforce NSPIRE requirements and compliance expectations. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2026
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over tenant recertifications to ensure: • Form HUD-50058 and supporting eligibility documentation are current, complete, and properly maintained for all tenants ...
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over tenant recertifications to ensure: • Form HUD-50058 and supporting eligibility documentation are current, complete, and properly maintained for all tenants • Timely processing of tenant move-outs and termination of HAP payments • Ongoing monitoring procedures to identify and promptly resolve instances of continued payments after program exit, including timely recovery of any overpayments Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA will conduct a review of the participant records to ensure Form HUD-50058 submissions and supporting eligibility documentation are attached, complete and accurate. Staff will use the Yardi Compliance Dashboard to monitor compliance, track processing timelines, and perform ongoing quality-control reviews. The agency will strengthen procedures for processing move-outs and program terminations through tracking mechanisms and supervisory oversight. Staff will receive training on HUD requirements related to tenant exits, terminations, and HAP processing. PBCHA will also perform monthly reconciliations of HAP payments, HUD-50058 terminations, and moveout records to identify and correct improper payments. These actions will help ensure accurate records, timely termination of assistance, prevention of overpayments, and compliance with HUD requirements. Name of the contact person responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2026
Finding 2025-003: Period of Performance – Significant deficiency in internal controls over compliance and compliance finding. Management Response The agency has added another level of review for Requests for Reimbursement (RFRs) to improve internal controls. Effective 10.01.2025, grant expense charg...
Finding 2025-003: Period of Performance – Significant deficiency in internal controls over compliance and compliance finding. Management Response The agency has added another level of review for Requests for Reimbursement (RFRs) to improve internal controls. Effective 10.01.2025, grant expense charges are processed as follows: 1. Finance Assistant creates grant Request for Reimbursement (RFR). Upon completion of the RFR, theAssistant signs the RFR as completed, then submits completed RFR along with supportingdocumentation to the EVP of Finance. Formerly, the creation of the RFR was being done by the EVP of Finance, with the addition of staff, we were able to relocate those duties to Finance Assistance in the Fall of 2025. 2. The EVP of Finance reviews the RFR for correct calculations and if the appropriate supportingdocumentation is attached. The EVP of Finance signs the RFR, then presents it to the ChiefOperating Officer for final approval. 3. Chief Operating Officer receives RFR from EVP of Finance, reviews RFR and approves for submissionto the Grantor or sends back for corrections. Adding a staff member in the Finance department allowed us to add another level of approval. In addition, notations have been made on all internal grant tracking documents, as to the start of each grant period. A payroll pay calendar is accessible to verify the exact dates covered on a pay period.
Finding 2025-001: Reporting – Material weakness in internal controls over compliance and compliance finding. Management Response Effective May 12, 2026, the agency enhanced its performance reporting oversight by requiring the Chief of Mission and the Executive Vice President of Victim Services to re...
Finding 2025-001: Reporting – Material weakness in internal controls over compliance and compliance finding. Management Response Effective May 12, 2026, the agency enhanced its performance reporting oversight by requiring the Chief of Mission and the Executive Vice President of Victim Services to review and approve preliminary reports to funding entities drafted by the compliance department, prior to submission. The agency’s compliance department, which consists of a Database Manager, Compliance Manager, and Executive Vice President of Compliance, is tasked with ensuring reliability and validity of client-level database entered in the client database. Monthly, the agency’s compliance department reconciles the number of new and unduplicated participants served by the agency as a whole and within each grant-funded program. The compliance department’s report originator will save the source data electronically, ensuring it matches the official figures submitted to the funding entity. Source data reports will be available upon request by agency staff and/or funders.
Corrective Action Plan Finding No: 2025-002 Condition: During the audit, the City did not verify that the contractor or subcontractor submitted the required certified payrolls for work performed under the federally assisted construction contract. As a result, the City did not maintain or review suff...
Corrective Action Plan Finding No: 2025-002 Condition: During the audit, the City did not verify that the contractor or subcontractor submitted the required certified payrolls for work performed under the federally assisted construction contract. As a result, the City did not maintain or review sufficient documentation to demonstrate compliance with wage rate requirements for all applicable weeks during the audit period. Management’s Plan: The City recognizes the need to improve internal controls related to grant disbursements for labor provided by our contractors. The project this past year included participation from multiple federal funding agencies and payments by the City as well as direct payments to contractors by the funding agencies. We have already added additional procedures and checkpoints to provide for adequate documentation related to certified payrolls. In addition, the City is planning to procure a grant tracking system to automate tracking the details for every project. Anticipated Date of Completion: 12/31/26 Name of Contact Person: Cheri Grieco, Finance Director
Corrective Action Plan Finding No: 2025-001 Condition: During the audit, our procedures indicated that capital expenditures were primarily reviewed at an individual invoice level to determine whether they exceeded the capitalization threshold. We also noted that communication between the City’s fina...
Corrective Action Plan Finding No: 2025-001 Condition: During the audit, our procedures indicated that capital expenditures were primarily reviewed at an individual invoice level to determine whether they exceeded the capitalization threshold. We also noted that communication between the City’s finance department and engineers or other City staff responsible for managing grants and capital projects is not consistently formalized. Management’s Plan: Management is committed to strengthening coordination and oversight of the City’s grant-funded capital projects through centralizing project tracking via grant/project management software, implementing rigorous compliance monitoring, and improving intradepartmental communication. By centralizing our grants through the course of their lifespans, we intend to better track the progress of our grant projects and budgets and with the inclusion of grant document storage, to enhance compliance across departments. We will also designate coordination teams consisting of liaisons across administration, finance, engineering, public works, and grant writers to ensure internal alignment. Anticipated Date of Completion: 4/30/2027 Name of Contact Person: Cheri Grieco, Finance Director
The YMCA and Affiliates’ have begun enhancing internal controls related to the reporting process through additional staff training, increased cross-training of personnel responsible for report preparation and submission, and the development of more formalized review procedures. Management has also r...
The YMCA and Affiliates’ have begun enhancing internal controls related to the reporting process through additional staff training, increased cross-training of personnel responsible for report preparation and submission, and the development of more formalized review procedures. Management has also reinforced expectations regarding reporting requirements and completeness prior to submission. These actions are intended to further strengthen consistency and oversight within the reporting process while building upon controls already in place.
The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended September 30, 2025. During the audit for PTV’s fiscal year 2025, it was determined that we should add an additional layer of confirmation to our a...
The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended September 30, 2025. During the audit for PTV’s fiscal year 2025, it was determined that we should add an additional layer of confirmation to our approval process. Currently, the President reviews invoices prior to signing the checks, thereby signaling approval. Moving forward, in addition to this review, the President will also confirm approval by initialing the invoice itself. Beyond this initial next step, PTV will also review its current Fiscal Policy to consider implementation of an approval process that allows other authorized approvers the authority to review expenses up to certain thresholds. Policy development at this level requires Finance Committee involvement and full Board approval, so it may take several months to fully implement a new process. We appreciate the opportunity to continue to strengthen PTV’s internal controls and financial operations.
The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended September 30, 2025. During the audit for PTV’s fiscal year 2025, it was determined that we should add an additional layer of confirmation to our a...
The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended September 30, 2025. During the audit for PTV’s fiscal year 2025, it was determined that we should add an additional layer of confirmation to our approval process. Currently, the President reviews invoices prior to signing the checks, thereby signaling approval. Moving forward, in addition to this review, the President will also confirm approval by initialing the invoice itself. Beyond this initial next step, PTV will also review its current Fiscal Policy to consider implementation of an approval process that allows other authorized approvers the authority to review expenses up to certain thresholds. Policy development at this level requires Finance Committee involvement and full Board approval, so it may take several months to fully implement a new process. We appreciate the opportunity to continue to strengthen PTV’s internal controls and financial operations.
2025-002 PROCUREMENT, SUSPENSION & DEBARMENT Condition: The Organization did not comply with the Davis-Bacon prevailing wage requirement Recommendation: The Organization executed the contract in question in June 2024, and the related project was completed in April 2025. The Organization's 2024 audit...
2025-002 PROCUREMENT, SUSPENSION & DEBARMENT Condition: The Organization did not comply with the Davis-Bacon prevailing wage requirement Recommendation: The Organization executed the contract in question in June 2024, and the related project was completed in April 2025. The Organization's 2024 audit was not issued until May 2025. Consequently, the Organization was not aware of the Davis-Bacon Act applicability during the period of contract execution and project performance and therefore did not have the opportunity to amend the contract to incorporate the Davis-Bacon Act requirements. In response to the findings identified in the prior year audit, the Organization has since implemented new policies and procedures to ensure timely identification of applicable compliance requirements for future contracts. Corrective Action Plan: The Director of Finance/CFO prepared a summary document regarding the federal guidelines on procurement, in particular highlighting this requirement concerning the Davis- Bacon act. Contact Person Responsible: Interim Director of Finance /CFO Completion date: June 30, 2025
2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. Documentation of verification through SAM.gov or equivalent methods could not be pr...
2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. Documentation of verification through SAM.gov or equivalent methods could not be provided by management. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors used on the project funded with federal awards. Recommendation: We recommend the Organization ensure the staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already established policies that the Organization has regarding such requirements. Corrective Action Plan: The contract associated with this finding was signed on January 24, 2025, before the 2024 financial audit was finished, so before the organization made changes to their procurement policy. Since then, the organization has reviewed its existing procurement policy, and updated it as necessary and will ensure that for future projects, the procurement policy will be carefully followed, including verification through SAM.gov. Staff involved in projects and procurement will receive training regarding the policies and the federal guidelines for federally funded projects. Contact Person Responsible: Interim Director of Finance /CFO Completion date: June 30, 2025
Utilize the snack count option within the Payschools program to obtain accurate counts. Cafeteria manager will go over the numbers before certifying for submission.
Utilize the snack count option within the Payschools program to obtain accurate counts. Cafeteria manager will go over the numbers before certifying for submission.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Supportive Housing for the Elderly Section 232 ALN Number: 14.129 Award Period: Year Ended December 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria ...
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Supportive Housing for the Elderly Section 232 ALN Number: 14.129 Award Period: Year Ended December 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: HUD requires a signed management fee agreement when such transactions take place. Condition: Unallowed related party transactions were identified in 2025. Context: Affiliate dues were booked to the Home's cash clearing account as a credit for $400,000 with the understanding that these fees would qualify as a service contract rather than a management fee. However, due to the cash infused into the program by The Carmelite System, the $400,000 will not be noted as questioned costs needing to be repaid into the project. Recommendation: The Home should adhere to the Regulatory Agreement and obtain HUD’s approval prior to taking any actions specifically precluded in the Regulatory Agreement. Action taken in response to finding: There is no disagreement with the audit finding. Management will work to obtain proper approval going forward. If the U.S. Department of Housing and Urban Development has questions regarding this schedule, please call Corrinne Schindler at 518-537-7500 or CSchindler@CarmeliteSystem.org.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Supportive Housing for the Elderly Section 232 ALN Number: 14.129 Award Period: Year Ended December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or sp...
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Supportive Housing for the Elderly Section 232 ALN Number: 14.129 Award Period: Year Ended December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Home was required to obtain written approval for the member substitution transaction with The Carmelite System, Inc. prior to closing. Condition: Membership transfer agreements must be in place and signed by HUD during the transition of Ownership / Governance. Context: Formal HUD approval was not obtained in relation the Member Substitution in which the Carmelite System, Inc. became the sole member and sponsor of the Home. Recommendation: The Home should adhere to the Regulatory Agreement and obtain HUD’s approval prior to taking any actions specifically precluded in the Regulatory Agreement. Action taken in response to finding: There is no disagreement with the audit finding. Management is working to obtain the necessary HUD approvals.
Management agrees with the finding and acknowledges that internal controls over inventory issuance were not consistently followed by an individual. While procedures existed requiring documentation of pick tickets, compliance with these procedures was not adequately enforced on a small number of tran...
Management agrees with the finding and acknowledges that internal controls over inventory issuance were not consistently followed by an individual. While procedures existed requiring documentation of pick tickets, compliance with these procedures was not adequately enforced on a small number of transactions. The Cooperative has begun strengthening its internal control processes to ensure that all inventory withdrawals are properly authorized and documented prior to release. In addition, management will implement monitoring procedures, including periodic reviews of inventory documentation, to ensure compliance with established controls. Training will also be provided to all relevant personnel to reinforce proper procedures and the importance of adherence to internal control requirements. Management expects these corrective actions to be fully implemented by May 15, 2026.
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