Corrective Action Plans

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Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based fili...
Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, verification of suspension and debarment status, and equitable distribution of micro- purchases. In addition, newly hired staff dedicated to Procurement and Accounts Payable have been onboarded to improve oversight and compliance. With these new systems, strengthened controls, and added staffing capacity, the College is now better positioned to maintain full compliance. Staff have been trained—and will continue to be trained twice a year—on procurement requirements and federal regulations to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institut...
Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system and strengthened internal controls to ensure all costs are properly aligned with the funding periods stipulated in the grant awards. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain accurate documentation and monitoring. Staff have been trained—and will continue to be trained twice a year— on compliance with federal grant requirements, including period of performance rules. These measures will ensure timely verification and prevent similar issues from recurring in future audits.
View Audit 370531 Questioned Costs: $1
Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to m...
Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to maintain complete and accurate capital asset records, conduct timely reconciliations, and strengthen asset safeguarding controls. Internal procedures have been enhanced to ensure periodic physical inventory, prompt updates, and independent reviews of capital asset records. The full reconciliation and migration of all capital asset data into the new system is actively ongoing and scheduled to be completed by December 2025. These measures will ensure compliance with federal property management requirements and prevent recurrence of similar issues in the future.
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionali...
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionalized a cloud- based filing system to ensure accurate recordkeeping, easy retrieval, and compliance with federal documentation requirements. Internal control procedures have been strengthened, and staff have received proper training, which will continue to be conducted twice a year on compliance with federal allowable cost principles and documentation standards. These measures will prevent recurrence of similar issues and ensure that all federal expenditures are adequately supported and fully compliant going forward.
View Audit 370531 Questioned Costs: $1
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly a...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly aligned with the purpose of the related subgrants. These gaps occurred because of inadequate internal controls and the limitations of the previous manual filing system, which made it difficult to locate and verify supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant- related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff have been trained and will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Views of Responsible Officials and Corrective Action: To address this issue and ensure future compliance, we have implemented the following measures: • Eligibility Verification Protocols: We have developed and implemented standardized eligibility screening procedures for all HHS-funded programs. The...
Views of Responsible Officials and Corrective Action: To address this issue and ensure future compliance, we have implemented the following measures: • Eligibility Verification Protocols: We have developed and implemented standardized eligibility screening procedures for all HHS-funded programs. These protocols include: • Clear definitions of eligibility criteria based on program guidelines. • Required documentation (e.g., income verification, residency, age, or disability status). • A checklist to ensure all required documents are collected and reviewed. • Documentation Standards: All eligibility determinations are now documented and retained in participant files. We have adopted a secure digital system to store and manage these records, ensuring they are accessible for audit and monitoring purposes . • Staff Training: Program staff have received training on eligibility requirements and documentation standards. Training materials include examples of acceptable documentation and instructions for handling incomplete or missing information. Monitoring and Oversight • We have instituted periodic internal audits to review participant files for compliance with eligibility documentation requirements. • Supervisors are required to review and approve eligibility determinations before services are rendered. Policy Updates Our program policies have been updated to include: • Mandatory eligibility screening and documentation procedures. • Retention requirements aligned with 2 CFR § 200.334. • Procedures for handling exceptions and documenting justifications. Commitment to Compliance We are committed to ensuring that all participants in HHS-funded programs meet the required eligibility criteria and that our documentation practices fully comply with Federal regulations. We appreciate the audit team's diligence and will continue to cooperate fully to resolve this finding.
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding regarding delays in completing the annual audit and submitting the required reporting package and data collection form to the Federal Audit Clearinghouse (FAC), as required under 2 CFR § 200.512. The o...
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding regarding delays in completing the annual audit and submitting the required reporting package and data collection form to the Federal Audit Clearinghouse (FAC), as required under 2 CFR § 200.512. The organization further recognizes that the audit and reporting package must be submitted within 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period, whichever is earlier. To address this issue and prevent recurrence, Us Helping Us will implement the following measures: Audit Timeline Planning: Us Helping Us has developed a detailed audit calendar with milestones for document preparation, auditor engagement, and internal review. The FY2023 Audit is scheduled for a December 2025 completion, FY2024 and FY2025 audits are scheduled for completion in March 2026 and August 2026 respectively. The organization is working on staffing improvements and plan on having key vacancies in our finance department filled and plan on providing training on audit readiness and Federal reporting requirements. Specifically, Us Helping Us is hiring for a Deputy Executive Director for Finance and Administration as well as a Finance Manager. These positions are scheduled to be filled by the end of September 2025. Next, Us Helping Us uses the updated FAC portal launched by the General Services Administration to ensure accurate and complete submissions In accordance with Federal guidance, Us Helping Us will documented the reasons for the delayed submission and retained this documentation for review by oversight agencies. We understand that while extensions may be granted under certain circumstances, timely submission is critical to maintaining our status as a low-risk auditee. Us Helping Us is committed to full compliance with Uniform Guidance and Federal audit requirements. The organization will continue to work to resolve this finding and ensure timely submissions in future years.
Views of Responsible Officials and Corrective Action: Us Helping Us has sought consultation from its contract CPA firm regarding this known time management issue. The organization is currently utilizing a payroll allocation system aligned with a time management system approved by current grantors fo...
Views of Responsible Officials and Corrective Action: Us Helping Us has sought consultation from its contract CPA firm regarding this known time management issue. The organization is currently utilizing a payroll allocation system aligned with a time management system approved by current grantors for reimbursements and reporting. Us Helping Us acknowledges the audit finding regarding the organization’s timekeeping and payroll allocation practices. Specifically, the absence of timesheets for each pay period and reliance on budget estimates for payroll allocation does not fully comply with the standards outlined in 2 CFR § 200.430(i) for compensation for personal services. Us Helping Us is in the process of implementing a timesheet system which will be supported by internal controls allowing for accurate, allowable and properly allocated time charges. To address this issue and ensure future compliance, Us Helping Us has implemented the following measures: The organization is to adopt a formal timekeeping policy requiring all employees whose salaries are charged to Federal awards to submit timesheets for each pay period. These timesheets must Reflect 100% of the employee’s compensated activities, be signed by both the employee and their supervisor, and distinguish between Federal and non-Federal activities. For employees working exclusively on a single Federal award, and for those working across multiple funding sources, detailed timesheets will be required for each pay period. While budget estimates may be used for interim accounting purposes, we now perform reconciliations to compare budgeted payroll allocations with actual time worked. Adjustments are made if discrepancies exceed 10% Staff involved in payroll and grant management will have received training on Federal time and effort reporting standards. We have also implemented internal controls to ensure consistent documentation and review. The system will comply with established accounting practices of Us Helping Us and reflect the total activity for which employees are compensated. The system will support the distribution of the Us Helping Us employee salaries among cost objectives, Federal awards, non-Federal awards, indirect and direct cost activities. The system will also allow for the appropriate maintenance of record keeping activities and supporting documentation. Us Helping Us’ financial policies have been updated to include requirements for time and effort documentation per 2 CFR § 200.430(i), procedures for reconciling payroll allocations with actual time worked and documentation retention standards aligned with 2 CFR § 200.302(b)(3). Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that personnel costs charged to Federal awards are accurate, allowable, and properly documented. The Executive Director and the Deputy Executive Director for Finance and Administration will be responsible for this Plan and will be effective immediately.
Views of Responsible Officials and Corrective Action: Us Helping Us first developed a Procurement Policy based on recommendations from a Site Visit from the Centers for Disease Control and Prevention in September 2017 and has been utilizing this policy since said time.Utilization faltered while Us H...
Views of Responsible Officials and Corrective Action: Us Helping Us first developed a Procurement Policy based on recommendations from a Site Visit from the Centers for Disease Control and Prevention in September 2017 and has been utilizing this policy since said time.Utilization faltered while Us Helping Us was in major transition during 2019 and 2020, due to the ongoing COVID-19 pandemic. The policy can be found on page 8 of the Us Helping Us Financial and Accounting Procedures Manual – March 2022 version submitted to auditors. Said procedures were revised in Fall 2022 and updated policies were submitted to the auditors. Us Helping Us acknowledges the audit finding regarding incomplete procurement documentation and the absence of a documented justification for sole source procurement. It is understood that compliance with 2 CFR § 200.320(c) and related Federal procurement standards is essential to ensure transparency, competition, and proper stewardship of Federal funds To address this issue and prevent recurrence, Us Helping Us’ procurement policy now explicitly requires written justification and documentation for all sole source procurements, in accordance with 2 CFR § 200.320(c) Staff involved in procurement will receive training on Federal procurement standards, including competitive and non-competitive methods. The organization will institute a procurement checklist to ensure all required documentation is completed and retained. Internal audits will include a review of procurement files for completeness and compliance. Us Helping Us is committed to maintaining full compliance with Federal procurement regulations and ensuring that all procurement actions are properly documented and justified. The Executive Director and the Deputy Executive Director for Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.
Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they ...
Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension or debarment. Us Helping Us acknowledges the audit finding regarding our organization’s inconsistent application of suspension and debarment screening procedures for vendors, suppliers, and contractors paid with Federal funds. We understand that compliance with 2 CFR Part 180 and 2 CFR § 200.214 is essential to ensure Federal funds are not awarded to parties that are suspended or debarred from doing business with the Federal Government. To further address this issue and prevent recurrence, Us Helping Us will implement the following measures: establishing a Standard Operating Procedure (SOP) for suspension and debarment checks, including when and how to perform them; integrated screening into the procurement workflow, requiring verification prior to contract execution or payment, designated staff responsible for performing and documenting checks using the System for Award Management (SAM.gov). Us Helping Us will now use one or more of the following Federally accepted methods for each covered transaction: SAM.gov search with screenshot documentation, Signed certification from the vendor affirming they are not suspended or debarred, and a Contract clause stating the vendor is not suspended or debarred, included in all Federally funded agreements. Training and Oversight will be provided to staff so that team members involved in procurement and grant management have received training on suspension and debarment requirements. An annual refresher training will be provided to ensure continued compliance. Internal audits will include a review of suspension and debarment documentation for all Federally funded transactions to ensure adherence. Our procurement policy has been updated to reflect mandatory suspension and debarment checks for all covered transactions, required documentation retention for audit purposes and procedures for verifying subrecipients and professional service providers. Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that Federal funds are only awarded to eligible entities. Us Helping Us maintains documentation of these searches, retain them in vendor files. Screenings will be conducted on an annual basis. Retrospective screenings were conducted as requested during the audit. In addition to access to SAM.gov, Us Helping Us is using the services of Office of Inspector General (OIG) Exclusion Search and Software Company. Services provided include OIG Searches as well as SAM and State Exclusion searches. Us Helping Us staff will be educated about these procedures.The Executive Director and the Deputy Executive Director for Finance and Administration, Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding based on fiscal year 2022, and not subsequent years, regarding missing supporting documentation for certain cash receipts. The organization understands the importance of maintaining complete and accura...
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding based on fiscal year 2022, and not subsequent years, regarding missing supporting documentation for certain cash receipts. The organization understands the importance of maintaining complete and accurate records to ensure financial transparency, accountability, and compliance with applicable regulations. Us Helping Us has developed the proper systems to ensure proper filing and maintenance of documentation supporting various expenditures.Of note, Us Helping Us has developed a process to track income receipts from various sources, including donors, and will be able to verify any donor mandated restrictions, and that contributions conform to said donors/payees. The organization uses a cloud-based accounting system and donor software that allows for attaching documentation directly to transactions. Us Helping Us has made progress in implementing systems for documentation, and as with expenses, documentation will be maintained electronically on the organization’s server, in the financial software used and filed in the Fiscal Manager’s office. All relevant staff will be trained on proper documentation procedures and the importance of retaining records for audit and compliance purposes. Further, financial policies will be updated to include a checklist of required documentation for all cash receipts, procedures for handling and documenting missing receipts an retention schedule aligned with IRS and GAAP requirements (minimum of three years after filing Form 990). Us Helping Us is committed to maintaining accurate and complete financial records. The Executive Director and the Deputy Executive Director for Finance and Administration are responsible for any developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding regarding missing supporting documentation for certain expenses, takes this matter seriously and is committed to ensuring full compliance with applicable accounting standards and Federal regulations. N...
Views of Responsible Officials and Corrective Action: Us Helping Us acknowledges the audit finding regarding missing supporting documentation for certain expenses, takes this matter seriously and is committed to ensuring full compliance with applicable accounting standards and Federal regulations. Noting that the findings are based on the 2022 fiscal year, since then the organization has developed the proper systems to ensure proper filing and maintenance of documentation supporting various expenditures. The organization has adopted several cloud-based accounting systems, specifically Quickbooks, Bill.com, and Google Drive, with integrated document management to ensure all expense records are stored and easily retrievable, in addition to maintaining physical files for applicable (non-online, virtual) expenses. In this regard, copies of contracts are maintained electronically on the organization’s server, in the financial software used and filed in the Fiscal Manager’s office.In addition, Us Helping Us maintains the appropriate internal controls to ensure that the appropriate documentation for general expenditures is maintained. Emphasis has been placed on strengthening current internal controls by requiring dual review of all expense submissions and enforcing a checklist for required documentation. All relevant staff undergo training on non-profit accounting standards, documentation protocols, and compliance requirements. Us Helping Us’ financial policies will include: Clear guidelines on acceptable documentation for expenses; Procedures for handling lost or missing records; and a retention schedule aligned with Federal requirements (e.g., Title 2 CFR § 200.333). Us Helping us is committed to maintaining transparency and accountability in all financial operations. The Executive Director and the Deputy Executive Director for Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which has been implemented.
2022-001: Data Collection Form and Single Audit Reporting Package VIEDA Response: The Authority recognizes the importance of timely Single Audit submissions to maintain compliance and low-risk auditee status. Delays in completing the audit process affected the FY2022, FY2023, and FY2024 cycles, and ...
2022-001: Data Collection Form and Single Audit Reporting Package VIEDA Response: The Authority recognizes the importance of timely Single Audit submissions to maintain compliance and low-risk auditee status. Delays in completing the audit process affected the FY2022, FY2023, and FY2024 cycles, and residual timing challenges may impact the FY2025 deadline. However, process improvements including a formal Single Audit calendar, monthly progress monitoring, and cross-training of staff are now in place and are expected to ensure full compliance beginning with the FY2026 audit cycle. Estimated Completion Date: Ongoing Contact: Kelly Thompson Webbe, Chief Financial Officer
The Council will insure that all future procurements correctly use and retain a procurement sheet which documents the item purchased, the bids received, as well as the analysis of the reasons for the winning bid. The winning contractor/vendor will be searched on the SAM website to determine that the...
The Council will insure that all future procurements correctly use and retain a procurement sheet which documents the item purchased, the bids received, as well as the analysis of the reasons for the winning bid. The winning contractor/vendor will be searched on the SAM website to determine that they are not suspended/debarred.
Management will be working with a consultant to update their written policies and procedures to be in compliance with the requirements of the Uniform Guidance.
Management will be working with a consultant to update their written policies and procedures to be in compliance with the requirements of the Uniform Guidance.
Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit...
Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit.
Management will ensure that all required grant reporting, both financial and/or narrative/programmatic will be prepared and submitted timely. The final reporting for the Treasury CARES ACT has been completed and submitted subsequent to year end.
Management will ensure that all required grant reporting, both financial and/or narrative/programmatic will be prepared and submitted timely. The final reporting for the Treasury CARES ACT has been completed and submitted subsequent to year end.
Management will ensure that all nongrant expenditures are kept to a minimum until the cash balance of NVT is in excess of the unearned grant revenue and restricted fund balance. A large part of this problem in the current year was the amount of money paid to the Village’s accountants/consultant in p...
Management will ensure that all nongrant expenditures are kept to a minimum until the cash balance of NVT is in excess of the unearned grant revenue and restricted fund balance. A large part of this problem in the current year was the amount of money paid to the Village’s accountants/consultant in prior years. This has been resolved and the new accountant’s fees are much more in line with reasonable amounts.
Planned Corrective Action: ACCEPT was approved by the Nevada Department of Public and Behavioral Health to submit RFRs as soon as possible in FY22. ACCEPT has followed this approval and submitted all requests by the 15th day of the month following the aforementioned month. Name of Contact Person: Gw...
Planned Corrective Action: ACCEPT was approved by the Nevada Department of Public and Behavioral Health to submit RFRs as soon as possible in FY22. ACCEPT has followed this approval and submitted all requests by the 15th day of the month following the aforementioned month. Name of Contact Person: Gwen Taylor, Executive Director
Planned Corrective Action: The Quality Management Director and Executive Director have worked together to create a process with appropriate checks and balances regarding moving expense across individual grants and major funds. This process will consist of multiple levels of approval and specific doc...
Planned Corrective Action: The Quality Management Director and Executive Director have worked together to create a process with appropriate checks and balances regarding moving expense across individual grants and major funds. This process will consist of multiple levels of approval and specific documentation. Any entries will be processed in a timely manner and all expenditure reports will be checked for errors monthly. This process will ensure that expenditure reports are accurate at the time they are submitted for reimbursement. Name of Contact Person: Gwen Taylor, Executive Director
Plan of Action: The District’s plan is a two-pronged approach to ensure that appropriate policies and procedures are in place and that recording of assets whose resources include federal funds will clearly indicate the federal award identification number, who holds the title, the participation rate,...
Plan of Action: The District’s plan is a two-pronged approach to ensure that appropriate policies and procedures are in place and that recording of assets whose resources include federal funds will clearly indicate the federal award identification number, who holds the title, the participation rate, the location, use, and condition that the asset is to be put to in accordance with uniform guidance. A. The District will implement a robust Capital Asset Policy to be reviewed and approved by the District’s Board of Directors. Standard Operating Procedures will accompany the policy and will be the standard guidelines in which all capital assets will be treated, regardless of where the funding resources are generated from. B. The District plans to use it’s accounting software, SAGE 50, and capital asset software, FAS, to document funding resources, which should include all the required information as noted in Uniform Guidance. Additionally, capital asset invoices will include proper documentation showing the funding resources and required information. Date of implementation: The policies and procedures will be reviewed by the Board of Directors no later than December 10, 2025, and will be retroactive to July 1, 2025, in order to consistently apply the policy and procedures to FY 2026. The District, if time will allow, may retroactively apply the policy to prior Fiscal Years.
We concur with the findings. MHHS Management has noted to HRSA that there’s a conflicting law in terms of the sliding fee and are working to change the legislation which will take time.
We concur with the findings. MHHS Management has noted to HRSA that there’s a conflicting law in terms of the sliding fee and are working to change the legislation which will take time.
We concur with reservations. While policy requires grantees to distribute micro-purchases equitably among qualified suppliers, during the reporting period it was necessary to secure supplies from any available and reliable source to meet urgent operational needs. This occurred during the pandemic, w...
We concur with reservations. While policy requires grantees to distribute micro-purchases equitably among qualified suppliers, during the reporting period it was necessary to secure supplies from any available and reliable source to meet urgent operational needs. This occurred during the pandemic, when Palau experienced significant supply chain disruptions, including delayed shipments and stock unavailability from most vendors. Consequently, micro-purchase awards were concentrated among a smaller group of suppliers able to meet immediate needs. Given Palau’s small market and limited supply availability, it is often necessary to procure from vendors who can consistently provide quality inventory.
View Audit 370385 Questioned Costs: $1
We concur with reservations. While policy calls for equitable distribution of micro-purchases, during the pandemic it was necessary to procure supplies from reliable vendors who could meet urgent operational needs. Supply chain disruptions and Palau’s small market meant awards were concentrated amon...
We concur with reservations. While policy calls for equitable distribution of micro-purchases, during the pandemic it was necessary to procure supplies from reliable vendors who could meet urgent operational needs. Supply chain disruptions and Palau’s small market meant awards were concentrated among a smaller group of suppliers able to provide timely and quality inventory.
View Audit 370385 Questioned Costs: $1
We concur with the finding. The ETA 9130 reports for FY22 were based on estimates due to limitations in the reliability of the WIOA accounting system at that time.
We concur with the finding. The ETA 9130 reports for FY22 were based on estimates due to limitations in the reliability of the WIOA accounting system at that time.
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