Corrective Action Plans

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Finding 395356 (2023-019)
Significant Deficiency 2023
2023-019 Oregon Housing and Community Services Ensure documentation is retained to support amounts reported MANAGEMENT RESPONSE: We agree with this recommendation. Staff have received training and documentation is now retained consistently to support reported figures. Anticipated Completion Date:...
2023-019 Oregon Housing and Community Services Ensure documentation is retained to support amounts reported MANAGEMENT RESPONSE: We agree with this recommendation. Staff have received training and documentation is now retained consistently to support reported figures. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller
Finding 395355 (2023-018)
Significant Deficiency 2023
2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training h...
2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the earmarking and obligation requirements as well. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller
Finding 395354 (2023-017)
Significant Deficiency 2023
2023-017 Oregon Housing and Community Services Ensure review of federal cash draws are adequately documented to support the draws are for the immediate cash needs of the program MANAGEMENT RESPONSE: We agree with this recommendation. Additional training has been provided to new team members, to e...
2023-017 Oregon Housing and Community Services Ensure review of federal cash draws are adequately documented to support the draws are for the immediate cash needs of the program MANAGEMENT RESPONSE: We agree with this recommendation. Additional training has been provided to new team members, to ensure adequate documentation exists to support immediate cash needs. Two-step verification of all draws is also required. Refresher training has been provided to staff to ensure oversight is in place at all times. The funds inadvertently drawn were corrected the first week of March 2024. Anticipated Completion Date: June 20, 2024 Contact person: Dean Criscola, Controller
View Audit 305129 Questioned Costs: $1
Finding 395353 (2023-027)
Significant Deficiency 2023
2023-027 Department of Human Services Improve controls to ensure eligibility criteria are met MANAGEMENT RESPONSE: We agree with this recommendation. The department previously submitted a work item (WI) to have a question in ONE that asks ‘yes/no’ if IEVS has been checked. The WI was approved and...
2023-027 Department of Human Services Improve controls to ensure eligibility criteria are met MANAGEMENT RESPONSE: We agree with this recommendation. The department previously submitted a work item (WI) to have a question in ONE that asks ‘yes/no’ if IEVS has been checked. The WI was approved and deployed into the system on April 17, 2024. The IEVS question will trigger and be required for TANF at certification, re-certification, and adding a person. The Quick Reference Guide for staff will be updated to reflect the new system functionality. Communication regarding the new system functionality will be provided to staff. The department previously submitted a change request (CR) to have the employability screening questions put into ONE as part of the TANF application/intake process. The CR has been approved and in final stages of design with the ONE system contractor, Deloitte. Once the WI is implemented into the system, the quick reference guide will be updated to reflect new system functionality. Communication regarding the new system functionality will be provided to staff. Anticipated Completion Date: December 31, 2024 Contact person: Xochitl Esparza, Program Administration Manager
View Audit 305129 Questioned Costs: $1
Finding 395352 (2023-026)
Significant Deficiency 2023
2023-026 Department of Human Services Improve controls relating to client not cooperating with child support requirements MANAGEMENT RESPONSE: We agree with this recommendation. The department previously identified the need for more training and has been taking steps to address the issue. Based o...
2023-026 Department of Human Services Improve controls relating to client not cooperating with child support requirements MANAGEMENT RESPONSE: We agree with this recommendation. The department previously identified the need for more training and has been taking steps to address the issue. Based on feedback from staff, the Child Support Quick Reference Guide has been updated to make it more user friendly and easier to follow. Training on processing child support tasks has been provided both statewide alongside Department of Child Support in November 2023 and with individual districts. In addition to materials and training, department policy is working reports of both outstanding child support tasks and tasks cleared without processing. The department continues to monitor the reports and provide follow up guidance to individual branches. The department has developed a take time for training (TT4T) that was delivered to staff on May 4, 2022, which is now outdated. The current TT4T will be removed, a new one will be created, and delivered to staff within the next 120 days. The department will also consider adding this material to the regional accuracy and timeliness training during the summer of 2024. The Oregon Eligibility Partnership (OEP) -Learning and Engagement Team (LET) reviewed the eligibility guide and will be revising materials within the next 120 days. OEP will review and revise the current lesson plan delivered to staff within the next 90 days. Anticipated Completion Date: September 30, 2024 Contact person: Xochitl Esparza, Program Administration Manager
View Audit 305129 Questioned Costs: $1
2023-025 Department of Human Services Obtain accurate information from the ONE application MANAGEMENT RESPONSE: We agree with this recommendation. The department continues to monitor and review ACF-199 and ACF-209 reports prior to submission. Defects identified through the monitoring and review p...
2023-025 Department of Human Services Obtain accurate information from the ONE application MANAGEMENT RESPONSE: We agree with this recommendation. The department continues to monitor and review ACF-199 and ACF-209 reports prior to submission. Defects identified through the monitoring and review process are logged into TFS and follow the defect management process. ONE/ODHS began SOC audit with an outside vendor at the end of 2023. The department is continuing to work through the items and anticipate completion with this audit by June 30, 2024. The department will share the findings once received if there are any. SOC audits will be done annually from here forward. The Agency provided a cure notice to Deloitte Consulting as the vendor related to the reports in December 2022 and considered the actions cured and removed the notice in July 2023. Quarterly reports sent through the contract have been provided and accepted by ACF. Defect triaging continues to be worked separately, and regular reports to verify changes, additional validations that were put into place, achieve expected quality in correct submission of data on behalf of Oregon from the ONE System. Anticipated Completion Date: December 31, 2024 Contact person: Xochitl Esparza, Program Administration Manager
2023-040 Oregon Department of Education State did not meet maintenance of effort requirement MANAGEMENT RESPONSE: We agree with this recommendation. The Department of Education agrees with this finding; however, context is critical to understand this requirement. The Maintenance of Effort (MOE) r...
2023-040 Oregon Department of Education State did not meet maintenance of effort requirement MANAGEMENT RESPONSE: We agree with this recommendation. The Department of Education agrees with this finding; however, context is critical to understand this requirement. The Maintenance of Effort (MOE) requirements in The ARP ESSER III legislation are unique. The purpose of the requirement is to ensure that states are not using the federal pandemic funds to replace state funding and then leaving districts with a more substantial “fiscal cliff” when the pandemic funds recede. ODE administers state funding to Oregon districts, but the levels and formulas governing the distribution of the total state funds are determined by the Oregon Legislature and not ODE. While the non-compliance finding implies that Oregon reduced education funding, that is not true. Education funding in Oregon did increase annually, yet not as much as other non-education funding priorities. The United States Department of Education (USDE) formula required to evaluate MOE does not adequately reflect the investment in public education in Oregon, nor does it acknowledge the complexities of Oregon’s state budget or school funding formulas. ODE worked closely with USDE staff monitoring MOE compliance and submitted a request to USED for an MOE waiver on March 14, 2024. We are awaiting a decision from USDE. A response is anticipated by June 2024. Anticipated Completion Date: June 30, 2024 Contact person: Cynthia Stinson, Senior Manager of Federal Investments and Pandemic Renewal Effort
Finding 395341 (2023-042)
Significant Deficiency 2023
2023-042 Oregon Department of Education Retain support for pre-approval of equipment purchases MANAGEMENT RESPONSE: We agree with this recommendation. ODE has already developed and implemented updates to the capital expenditure request review and approval process to ensure equipment approvals are...
2023-042 Oregon Department of Education Retain support for pre-approval of equipment purchases MANAGEMENT RESPONSE: We agree with this recommendation. ODE has already developed and implemented updates to the capital expenditure request review and approval process to ensure equipment approvals are retained. Early ESSER capital project tag requests were split between a committee for large projects and the individual grant finance manager. Approvals were primarily sent via email from the grant finance manager. Some of those messages are archived in the ESSER.ODE inbox, however some went out directly from staff email. Records are available for the committee decisions. When the smaller approvals moved from the finance manager to an ESSER team, many of those decisions were made in conjunction with other meetings. Some records are available; however, the Capital Expenditure Tracker was the primary location of decisions. In October 2022, staffing changes allowed the committee and team structure to become more formalized. Committee meeting decisions shifted from a “minute”- style agenda to being more systematized in an online log. Team meeting decisions followed a similar process update in April 2023. The online agenda/log allows for consistent tracking of projects that are up for discussion and which approval are put on hold for elevation approval, correction, or clarification from the district. Committee and team meetings have been established weekly. When all information is received from a district, the project is placed on the appropriate agenda for that week. Approvals are sent out within 2 business days. A column was added to the Capital Expenditure Tracker, which remains the primary location of records, to track when the approval emails were sent. Corrections have already been developed and implemented as of April 2024. Anticipated Completion Date: April 30, 2024 Contact person: Cynthia Stinson, Senior Manager of Federal Investments and Pandemic Renewal Effort
Finding 395340 (2023-041)
Significant Deficiency 2023
2023-041 Oregon Department of Education Improve FFATA reporting controls MANAGEMENT RESPONSE: We agree with this recommendation. ODE will implement the following corrective action to ensure monthly FFATA reports are independently reviewed to ensure accurate and complete reporting. 1. Review and u...
2023-041 Oregon Department of Education Improve FFATA reporting controls MANAGEMENT RESPONSE: We agree with this recommendation. ODE will implement the following corrective action to ensure monthly FFATA reports are independently reviewed to ensure accurate and complete reporting. 1. Review and update list of all FFATA eligible federal awards monthly. 2. Implement a new query tool that will reduce manual processes. 3. Collaborate with ODE partners to access agency-collected unique entity identifier (UEI) information for sub awardees. 4. Monthly review of FFATA reporting by a second accountant. Anticipated Completion Date: June 30, 2024 Contact person: Kristie Miller, Accounting Director
2023-032 Oregon Commission for the Blind Seek clarification from federal awarding agency on appropriateness of legal fees MANAGEMENT RESPONSE: We agree with this recommendation. The agency believes it is allowable to use VR funds for legal fees based upon the guidance provided by 2 CFR § 200.459,...
2023-032 Oregon Commission for the Blind Seek clarification from federal awarding agency on appropriateness of legal fees MANAGEMENT RESPONSE: We agree with this recommendation. The agency believes it is allowable to use VR funds for legal fees based upon the guidance provided by 2 CFR § 200.459, which allows for professional service costs. The agency has previously asked for clarification regarding this issue from the Rehabilitation Services Administration, and we are awaiting their response. We will contact them again requesting clarification. The completion date for this finding is dependent upon receipt of clarification and guidance from the Rehabilitation Services Administration. Anticipated Completion Date: December 31, 2024 Contact person: Dacia Johnson, Executive Director
View Audit 305129 Questioned Costs: $1
Finding 395338 (2023-031)
Significant Deficiency 2023
2023-031 Oregon Commission for the Blind Improve controls over compliance reporting MANAGEMENT RESPONSE: We agree with this recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate and well supported. The agency’s practice is to maintain documenta...
2023-031 Oregon Commission for the Blind Improve controls over compliance reporting MANAGEMENT RESPONSE: We agree with this recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate and well supported. The agency’s practice is to maintain documentation that supports information contained in the case management system. This practice includes requesting information from clients regarding the start date of employment in the primary occupation and the hourly wage at exit. This information can be difficult to locate due to the numerous case notes in the case management system. Due to the difficulty locating this documentation in the tight timelines of the audit, the agency spent some additional time attempting to locate it after the audit testing period had closed. The agency did find the supporting documentation for one of the two clients that was not located during the audit. For the other client, the agency identified documentation showing that we had requested this information from the client through multiple methods, but it was never received. The agency has created a new case-note category for documenting client employment start date and wages at exit. The agency will provide training to staff on the use of this case note category to ensure this documentation is able to be located more easily and to reinforce the importance of maintaining documentation to support information contained in the case management system. Anticipated Completion Date: August 1, 2024 Contact person: Angel Hale, Director of Vocational Rehabilitation Services
Finding 395337 (2023-030)
Significant Deficiency 2023
2023-030 Department of Human Services Strengthen controls over payroll expenditures MANAGEMENT RESPONSE: We disagree with this finding. This finding pertained to two State Independent Living Council (SILC) board members paid with VR Innovation & Expansion funding. Upon review of the Rehabilitati...
2023-030 Department of Human Services Strengthen controls over payroll expenditures MANAGEMENT RESPONSE: We disagree with this finding. This finding pertained to two State Independent Living Council (SILC) board members paid with VR Innovation & Expansion funding. Upon review of the Rehabilitation Act and 34 CFR 361.35 section (a) part (2), funding may be used “To support the funding of the State Rehabilitation Council, if the State has a Council, consistent with the resource plan identified in § 361.17(i) “ The SILC State Plan cover 2021-2023 references Innovation and Expansion funding on pages 5 and 6. Based on the department’s review we believe the VR funding used is appropriate and that no further corrective action is required. Anticipated Completion Date: N/A Contact person: Keith Ozols, Vocational Rehabilitation Services Director
View Audit 305129 Questioned Costs: $1
2023-029 Department of Human Services Strengthen controls over program expenditures MANAGEMENT RESPONSE: We agree with this recommendation. Questioned costs consist of facility payments totaling $139 and a separate payment which exceeded costs of client services by $10. The agency agrees with th...
2023-029 Department of Human Services Strengthen controls over program expenditures MANAGEMENT RESPONSE: We agree with this recommendation. Questioned costs consist of facility payments totaling $139 and a separate payment which exceeded costs of client services by $10. The agency agrees with the finding and will refund those questioned costs. The agency will review the specific circumstances for each of the invoices paid to ensure staff receive the appropriate training as well as reiterate the need to review invoices carefully according to current policies and practices to avoid coding errors. Anticipated Completion Date: June 30, 2024 Contact person: Keith Ozols, Vocational Rehabilitation Services Director
View Audit 305129 Questioned Costs: $1
2023-028 Department of Human Services Strengthen controls to ensure adequate supporting documentation and accuracy over reporting MANAGEMENT RESPONSE: We agree with the first recommendation. We disagree with the second recommendation. We agree with the first recommendation and will ensure adequa...
2023-028 Department of Human Services Strengthen controls to ensure adequate supporting documentation and accuracy over reporting MANAGEMENT RESPONSE: We agree with the first recommendation. We disagree with the second recommendation. We agree with the first recommendation and will ensure adequate supporting documentation is maintained and readily available to support information reported in the RSA-911. We disagree with the second recommendation. The RSA-17 is currently reviewed by both Program Leadership as well as the ODHS Grant Accounting Manager. Certification is evidenced by the signed RSA-17. This level of review meets federal requirements. Additional review and discussion may be had as a form of best practice but should not be considered a control mechanism. The Grant Accounting Unit will highlight the certification process in the RSA-17 desk manual to delineate between control functions and best practices. Anticipated Completion Date: June 30, 2024 Contact person: Keith Ozols, Vocational Rehabilitation Services Director; Travis Labrum, Grant Accounting Manager
Finding 395334 (2023-043)
Significant Deficiency 2023
2023-043 Oregon Business Development Department Management should implement accounting review of quarterly reports before submitting to DAS MANAGEMENT RESPONSE: We agree with this recommendation. We agree with this finding. Business Oregon has gone through significant personnel change during the ...
2023-043 Oregon Business Development Department Management should implement accounting review of quarterly reports before submitting to DAS MANAGEMENT RESPONSE: We agree with this recommendation. We agree with this finding. Business Oregon has gone through significant personnel change during the period of American Rescue Plan Act (ARPA) grant disbursements, from January 2022 to June 2023. The Chief Financial Officer, Accounting Manager, and Accountants had moved on to other state agencies. The accounting positions were left vacant for months due to challenges in timely filling these positions with the right skill sets. Although there were only a few accounting staff left when majority of the grant disbursements were made, the remaining accounting processed the disbursements with very tight deadlines. The accounting staff processed grant disbursements through appropriate internal control procedures, reviewed supporting documents for appropriate signature approval on the requests, and made accounting entries for these grant activity transactions. Below is a list of staff hire dates to illustrate the turnover we faced during this time period: • Federal Grant Accountant – November 2023 • Chief Financial Officer – October 2023 • Deputy CFO/Accounting Manager – May 2023 • Program Accountant 2 – April 2023 • Accounting Technician – April 2023 • Debt Accountant 3 – March 2023 • Program Accountant 3 – January 2023 • Program Accountant 3 – August 2022 Due to the accounting team not having enough personnel at the time to prepare reports for the DAS ARPA Grant Program Coordinator, Business Oregon program staff (not accounting staff) took the initiative to complete the reports and submitted the periodic/quarterly reports to DAS. As the Business Oregon program staff did not have access to the SFMA (state accounting system), the program staff used data from another system (Salesforce, not an accounting system) to fill the needed information for the reports. The initial reports submitted to DAS were not reviewed by accounting staff. The program staff continued to complete the reports for DAS until first quarter of 2023, until accountant positions were filled in 2023. While preparing for the FY 2023 Year-End Closing process (June 2023 to July 2023), the newly hired accountants and Deputy CFO/Accounting Manager reviewed as many FY23 financial transactions as they could and made necessary adjustments and accounting entry corrections. Reporting discrepancies were identified between department accounting records and the reports submitted by program staff to DAS/US Dept of Treasury. Business Oregon accountants worked with DAS on revising the SEFA reports and identified ARPA grant-related items that needs to be corrected. The research continued even after the fiscal year 2023 reporting has closed. A reconciliation of records between department accounting and the reports submitted to the DAS Grant program coordinator was completed in January 2024, and the Business Oregon accounting team submitted a revised FY 2023 SEFA report corrections to the DAS SARS team. Going forward, management will ensure that the completion of quarterly financial reports for grant reporting is performed and submitted by the agency’s accounting team and not program staff to ensure data comes from the accounting system with the review by an accountant or accounting manager. Anticipated Completion Date: June 30, 2024 Contact person: Imee Anderson, Chief Financial Officer; Karl Mielke, Deputy Chief Financial Officer
Finding 395333 (2023-044)
Significant Deficiency 2023
2023-044 Oregon Housing and Community Services Ensure that the nature of program applicants' financial hardship is documented MANAGEMENT RESPONSE: The agency agrees with this finding. OHCS completed research to better isolate the problem and verified the nature of hardship fields are required to...
2023-044 Oregon Housing and Community Services Ensure that the nature of program applicants' financial hardship is documented MANAGEMENT RESPONSE: The agency agrees with this finding. OHCS completed research to better isolate the problem and verified the nature of hardship fields are required to submit an application in the homeowner application portal. Review of the hardship fields are now required, and program underwriters and housing counselors will request hardship statements where none exist in an application. The HAF team will review funded applications to determine if any deficiencies exist related to attestations of the nature of financial hardship. OHCS will request that those applicants supplement any missing information to adhere to regulatory standards. OHCS will also implement sampling quality assurance, compliance, and data report reviews to check for attestations of the nature of financial hardships. Anticipated completion date: September 30, 2024 Contact person: Ryan Vanden Brink, Grants, Loans, and Program Manager
2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery MANAGEMENT RESPONSE: We agree with this recommendation. OHCS is in the process of coordinating with agencies and contractor to resolve any outstanding compliance concerns. Expenses ...
2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery MANAGEMENT RESPONSE: We agree with this recommendation. OHCS is in the process of coordinating with agencies and contractor to resolve any outstanding compliance concerns. Expenses may be considered mitigated if documentation to support the questioned cost is obtained, or if agency is able to clarify policy and procedure to support existing documentation. If expenditure is not resolved and is identified as non-compliant with federal requirements, OHCS may pursue cost recovery. Anticipated Completion Date: July 31, 2024 Contact person: Liz Weber, Chief Policy Officer
View Audit 305129 Questioned Costs: $1
2023-016 Oregon Housing and Community Services Verification that subrecipients have not been suspended or debarred needs to be retained MANAGEMENT RESPONSE: We agree with this recommendation. Since the original findings in 2022, we have added the SAM check as a mandatory review activity in our a...
2023-016 Oregon Housing and Community Services Verification that subrecipients have not been suspended or debarred needs to be retained MANAGEMENT RESPONSE: We agree with this recommendation. Since the original findings in 2022, we have added the SAM check as a mandatory review activity in our agreement trackers and have provided training and guidance as to the retention of the screenshots of the SAM check as of 6/30/2023. As we have experienced some additional staff turnover since then, we will reiterate that guidance; document the requirement in a team procedure; and provide a refresher as to the necessity of this document retention on a recurring basis. This will currently be in the Procurement Administrative files but is subject to change as there is a project in motion at OHCS for a Grant Management System that may inform a procedural change as to how and where we retain and archive agreement documentation. Anticipated Completion Date: June 30, 2024 Contact person: Liz Weber, Chief Policy Officer
2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in...
2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in time to complete action prior to end of audit work, however work will be finalized prior to the end of the current fiscal year. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller
Finding 395329 (2023-039)
Significant Deficiency 2023
2023-039 Oregon Health Authority Ensure program payroll costs are incurred only for program staff MANAGEMENT RESPONSE: We agree with this recommendation. WIC Leadership is dedicated to reviewing and integrating existing reports into their time review process and will also ensure that staff respon...
2023-039 Oregon Health Authority Ensure program payroll costs are incurred only for program staff MANAGEMENT RESPONSE: We agree with this recommendation. WIC Leadership is dedicated to reviewing and integrating existing reports into their time review process and will also ensure that staff responsible for employee time approval have been adequately trained on how to use those reports and features in Workday to review time. Questioned costs will be refunded. Anticipated Completion Date: September 30, 2024 Contact person: Tiare Sanna, Public Health Manager
View Audit 305129 Questioned Costs: $1
Standard Operating Procedures to monitor and update the Institution’s property records are currently established in place as part of the Fixed Asset Policy. In addition, federal sponsored projects will update the inventory records each trimester.
Standard Operating Procedures to monitor and update the Institution’s property records are currently established in place as part of the Fixed Asset Policy. In addition, federal sponsored projects will update the inventory records each trimester.
During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certific...
During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certification process. This activity will be aligned to the recent updates of the electronic platform.
A user guide will be established describing the steps to assembly the academic year in Banner system. This document will detail all the validation tables, processed at the registrar’s office, that impact the financial aid office procedures. Each associate registrar will have access to this guide. ...
A user guide will be established describing the steps to assembly the academic year in Banner system. This document will detail all the validation tables, processed at the registrar’s office, that impact the financial aid office procedures. Each associate registrar will have access to this guide. The institutional registrar will be in charge of disseminating this guide across all campuses and locations. The Registrar office will notify Financial Aid, once they validate the table assembly is completed in Banner.
The reconciliation process and procedure of returned funds was reviewed by the accounting, bursar, and financial aid areas. The returned check process was reviewed and updated accordingly.
The reconciliation process and procedure of returned funds was reviewed by the accounting, bursar, and financial aid areas. The returned check process was reviewed and updated accordingly.
Starting on year 2023-2024, the designated qualified individual in the information technology department will prepare an annual written report for the board of directors to inform material matters of the information security program.
Starting on year 2023-2024, the designated qualified individual in the information technology department will prepare an annual written report for the board of directors to inform material matters of the information security program.
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