Corrective Action Plans

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We hired a new HCV Program Director and they are working with the Field Office with a goal of the 2026 SEMAP score getting us out of trouble designation.
We hired a new HCV Program Director and they are working with the Field Office with a goal of the 2026 SEMAP score getting us out of trouble designation.
In January of 2025 we created an internal compliance department and started discovering we had a compliance problem. In March we had AMA Consulting Group start the process of identifying the problem and their report is dated March 13, 2025. We are currently working to ensure all files are accurate a...
In January of 2025 we created an internal compliance department and started discovering we had a compliance problem. In March we had AMA Consulting Group start the process of identifying the problem and their report is dated March 13, 2025. We are currently working to ensure all files are accurate and have developed a four-phase corrective action process that we have implemented. The corrective action is working and we anticipate completion by September 30, 2026.
Corrective Action Plan WK&T respectfully submits the following corrective action plan for the year ended December 31, 2025. Finding: 2025-001 –Suspension and Debarment Responsible Individuals: Bhavini Sokhey, Chief Financial Officer Anticipated Completion Date: Implemented Finding Summary: Lack of d...
Corrective Action Plan WK&T respectfully submits the following corrective action plan for the year ended December 31, 2025. Finding: 2025-001 –Suspension and Debarment Responsible Individuals: Bhavini Sokhey, Chief Financial Officer Anticipated Completion Date: Implemented Finding Summary: Lack of documented policies and procedures related to suspension and debarment Corrective Action Plan: •The Company has developed and implemented formal written policies and procedures to addresscompliance with federal suspension and debarment requirements. •Prior to awarding any contract funded with federal or state funds, the Company will verify that thevendor or contractor is not suspended or debarred by reviewing the SAM.gov Exclusions database.Documentation of the verification will be retained in the procurement file. •The Company will require all contractors participating in federally or state-funded projects toexecute a certification confirming they are not debarred, suspended, proposed for debarment,declared ineligible, or voluntarily excluded from participation in such programs. •The procurement and grant administration staff are responsible for performing and documentingthese procedures. Compliance will be reviewed as part of the Company's procurement process andongoing grant oversight to ensure adherence to federal and state requirements.
2025-004 – COMPLIANCE AND CONTROLS OVER REPORTING Corrective Action Plan: The Organization has developed a centralized reporting calendar identifying all required report filing deadlines. Designated staff will utilize the reporting calendar to monitor and ensure the timely submission of all required...
2025-004 – COMPLIANCE AND CONTROLS OVER REPORTING Corrective Action Plan: The Organization has developed a centralized reporting calendar identifying all required report filing deadlines. Designated staff will utilize the reporting calendar to monitor and ensure the timely submission of all required reports. The reporting calendar will be incorporated into the Organization's succession planning and reviewed regularly to ensure compliance with all reporting requirements and continuity during staff transitions. Responsible Party(ies): • Executive Director • Finance Manager Anticipated Date of Completion: September 30, 2026
2025-003 INTERNAL CONTROLS OVER PAYROLL AND BENEFITS ALLOCATIONS Corrective Action Plan: The Organization has implemented a pre-payroll review process requiring supervisors to verify the accuracy of employee timesheets before submitting them to the Finance Manager. The Finance Manager will conduct a...
2025-003 INTERNAL CONTROLS OVER PAYROLL AND BENEFITS ALLOCATIONS Corrective Action Plan: The Organization has implemented a pre-payroll review process requiring supervisors to verify the accuracy of employee timesheets before submitting them to the Finance Manager. The Finance Manager will conduct a secondary review of timesheets before entering and processing payroll. In addition, the Organization has implemented a new benefits software administration system to improve the accuracy of benefit tracking and allocations. Any discrepancies identified during the review process will be corrected promptly before payroll is finalized. Responsible Party(ies): • Finance Manager Anticipated Date of Completion: September 30, 2026
Condition: We noted that the applicable wage determination information was not included in the funding agreement and related contract documentation for the project selected for testing. The City relied on Alabama Department of Transportation (ALDOT) to ensure all federally required provisions were i...
Condition: We noted that the applicable wage determination information was not included in the funding agreement and related contract documentation for the project selected for testing. The City relied on Alabama Department of Transportation (ALDOT) to ensure all federally required provisions were included in the bid specifications and contracts. Although certified payrolls were submitted and the contractor complied with prevailing wage requirements, the required documentation was not formally included in the agreement package. Criteria: Federal regulations require that contracts and subcontracts for construction projects in excess of $2,000 financed with federal assistance funds include the applicable prevailing wage provisions and wage determinations under the Wage Rate Requirements (Davis-Bacon Act). In addition, contractors and subcontractors are required to submit weekly certified payrolls for each week work is performed. These requirements are established by 40 USC 3141-3147; 29 CFR Part 5; and 2 CFR section 200.326. Cause: The City relied on ALDOT's review and approval process for inclusion of required federal labor standard provisions and did not perform an independent verification that all Wage Rate Requirement provisions and wage determinations were included in the executed agreements.Effect: Failure to include all required Wage Rate Requirement provisions and documentation in construction agreements could result in noncompliance with federal requirements and increases the risk that contractors may not be properly informed of applicable prevailing wage requirements. Recommendation: We recommend the City implement procedures to independently verify that all federally required contract provisions, including applicable wage determinations and Davis-Bacon provisions, are included in bid specifications, contracts, and funding agreements prior to execution, even when projects are administered in coordination with third parties such as ALDOT. View of Responsible Officials and Planned Corrective Action: Management stated the project was administered through ALDOT and the City historically relied on ALDOT to ensure all required federal provisions were included in project documentation. Management noted that the funding agreement for this project did not include the wage determination information, although ALDOT later confirmed the requirements were applicable and certified payrolls were submitted. Management further indicated the contractor regularly performs ALDOT work and complied with the requirements. The City has updated its procedures to independently verify inclusion of all required federal compliance provisions going forward
New automated financial systems have been implemented to reduce error, and management has added an additional review step for all federal reimbursement requests to verify that payroll and fringe benefit costs are accurately calculated and allocated before submission. Reimbursement requests have and ...
New automated financial systems have been implemented to reduce error, and management has added an additional review step for all federal reimbursement requests to verify that payroll and fringe benefit costs are accurately calculated and allocated before submission. Reimbursement requests have and will be reconciled to payroll reports, time records, and allocation schedules to ensure costs are not duplicated. Staff responsible for grant financial reporting have been reminded of the required review procedures, and the Finance and/or Executive Director will perform a secondary review of all reimbursement requests. These measures are intended to prevent duplicate charges and ensure compliance with federal allowable cost requirements.
Cash Management Drawdowns from G5 Planned Corrective Action: Management acknowledges the audit finding regarding the inability to provide documentation demonstrating that Federal Direct Loan and Pell Grant funds were disbursed to students within the required timeframe following drawdown. While the C...
Cash Management Drawdowns from G5 Planned Corrective Action: Management acknowledges the audit finding regarding the inability to provide documentation demonstrating that Federal Direct Loan and Pell Grant funds were disbursed to students within the required timeframe following drawdown. While the College performed end-of-term reconciliations between student accounts and G5 to ensure no excess cash was maintained, documentation supporting timely disbursement at the student level was not consistently retained. Under the leadership of the Assistant Vice President (AVP) for Financial Aid and the AVP for Finance, the College has implemented a revised operating procedure to track cash management drawdowns on a student-by-student basis. A shared tracking workbook is now used by both offices to coordinate drawdowns and monitor the timing of disbursements. This enhanced process provides improved documentation and oversight to ensure compliance with federal requirements, including the timely disbursement of funds. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid, Landee Buzhardt, Director of Student Accounts, and Carrie Morris, AVP for Finance Anticipated Date of Completion: Completed.
Need Analysis Planned Corrective Action: Management acknowledges the audit finding related to errors in need analysis, including instances of over-awarded Federal Direct Loans and under-awarded Pell Grants. These errors were the result of deficiencies in oversight and review processes within the Fin...
Need Analysis Planned Corrective Action: Management acknowledges the audit finding related to errors in need analysis, including instances of over-awarded Federal Direct Loans and under-awarded Pell Grants. These errors were the result of deficiencies in oversight and review processes within the Financial Aid Office during the audit period. The identified discrepancies have been corrected. To address this issue, the College has implemented significant changes within the Financial Aid Office, including elevating leadership to the Assistant Vice President (AVP) level and hiring experienced, qualified staff. These changes strengthen both technical expertise and supervisory capacity. Additionally, the College has enhanced review procedures related to awarding, including increased oversight of need analysis calculations and enrollment verification prior to disbursement. These measures are intended to improve accuracy and ensure compliance with Title IV requirements. Management believes these corrective actions have addressed the root causes of the finding and will continue to monitor awarding processes to ensure ongoing compliance. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid Anticipated Date of Completion: June 30, 2026
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Management acknowledges the audit finding regarding an inaccurate Return of Title IV (R2T4) calculation. In the instance identified, an incorrect number of days was used for a student enrolled in a modular course, resulting in an ...
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: Management acknowledges the audit finding regarding an inaccurate Return of Title IV (R2T4) calculation. In the instance identified, an incorrect number of days was used for a student enrolled in a modular course, resulting in an over-return of $332 in Federal Direct Loans and $419 in Pell Grant funds. The College has addressed this issue through a comprehensive restructuring of the Financial Aid Office. Leadership of the office has been elevated from a director-level position to an Assistant Vice President (AVP) role, and the office has been restaffed with experienced and qualified personnel. In addition, the College has reinforced training and review procedures related to R2T4 calculations, including increased supervisory oversight to ensure accuracy, particularly for students enrolled in modular coursework. Ongoing monitoring will be performed to ensure continued compliance. Person Responsible for Corrective Action Plan: Missy Perry, AVP for Financial Aid Anticipated Date of Completion: June 30, 2026
Enrollment Reporting to NSLDS Planned Corrective Action: Management acknowledges the audit finding regarding untimely and inaccurate reporting of enrollment information to the National Student Loan Data System (NSLDS). The issue was primarily due to a lack of awareness regarding discrepancies betwee...
Enrollment Reporting to NSLDS Planned Corrective Action: Management acknowledges the audit finding regarding untimely and inaccurate reporting of enrollment information to the National Student Loan Data System (NSLDS). The issue was primarily due to a lack of awareness regarding discrepancies between reporting through the National Student Clearinghouse to the NSLDS, as well as complications following the College’s recent upgrade to Jenzabar One (J1). After the upgrade, certain internal reports did not function as expected, and resolving these reporting issues required additional time and coordination between the Director of Institutional Research (IR) and the Registrar. The Director of IR has continued to work in coordination with the Registrar and the Assistant Vice President (AVP) for Financial Aid to ensure accurate and timely reporting to both NSLDS and the Clearinghouse. The Director of IR now provides biweekly status reports to the Vice President for Administration to support ongoing oversight and accountability. Person Responsible for Corrective Action Plan: Kristy Parker, Registrar Anticipated Date of Completion: June 30, 2026
2025-001 – ALN 14.850 – Public Housing Operating Fund – Activities Allowed or Unallowed Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. The Authority is now drawing down its CFP and is not usin...
2025-001 – ALN 14.850 – Public Housing Operating Fund – Activities Allowed or Unallowed Planned Corrective Action: The Executive Director acknowledges the finding and is following the auditor’s recommendation as presented in the Audit Report. The Authority is now drawing down its CFP and is not using operating funds for CFP activities. Person Responsible for Correction of Finding: Wanda Allen, Executive Director Anticipated Completion Date: September 30, 2026
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS – ALL FEDERAL PROGRAMS 2025-001 Reporting Compliance Requirement Finding Summary 2 CFR § 200.510 requires that the City of South St. Paul, Minnesota (the City) prepare appropriate annual financial stat...
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS – ALL FEDERAL PROGRAMS 2025-001 Reporting Compliance Requirement Finding Summary 2 CFR § 200.510 requires that the City of South St. Paul, Minnesota (the City) prepare appropriate annual financial statements, including the Schedule of Expenditures of Federal Awards (SEFA), which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. During our audit, we noted the City did not have sufficient controls in place to ensure the accurate preparation of the SEFA in compliance with this requirement. The City’s SEFA for fiscal 2025 was overstated by $749,656 in federal expenditures, due to the inclusion of costs that were incurred in the previous fiscal year. Corrective Action Plan Actions Planned – The City has implemented new processes and procedures in 2026 which address this internal control finding to comply with the Uniform Guidance in the future. Finance department personnel will work with federal grant coordinators to assure that federal expenditures are accurately reported on the SEFA for all federal programs. Official Responsible – Clara Hilger, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – The City’s Finance Director, Clara Hilger, will ensure the new process and procedures implemented in this area ensure future compliance with the Uniform Guidance.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF TRANSPORTATION – PASSED THROUGH MINNESOTA DEPARTMENT OF TRANSPORTATION – HIGHWAY PLANNING AND CONSTRUCTION FEDERAL ALN 20.205 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements F...
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF TRANSPORTATION – PASSED THROUGH MINNESOTA DEPARTMENT OF TRANSPORTATION – HIGHWAY PLANNING AND CONSTRUCTION FEDERAL ALN 20.205 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the City to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the Highway Planning and Construction federal program. During our audit, we noted the City did not have sufficient controls in place within this program to ensure compliance with federal requirements related to assuring that the City was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The City has implemented new processes and procedures in 2026 which address this internal control finding to ensure compliance with the Uniform Guidance in the future. The procedures will include steps to assure that City personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Clara Hilger, Finance Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – The City’s Finance Director, Clara Hilger, will oversee the evaluation of this process, and the implementation of any procedural changes deemed necessary to ensure the City’s control procedures over suspension and debarment are performed and adequately documented in the future.
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed...
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Finding 2025-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part ...
Finding 2025-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Finding 2025-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the...
Finding 2025-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Finding 1221699 (2025-001)
Material Weakness 2025
Views of Responsible Officials: Management appreciates the auditors' recommendations and recognizes the importance of consistently documenting supervisory review and approval of employee timesheets.The finding relates to the documentation and retention of supervisory approval for certain employee ti...
Views of Responsible Officials: Management appreciates the auditors' recommendations and recognizes the importance of consistently documenting supervisory review and approval of employee timesheets.The finding relates to the documentation and retention of supervisory approval for certain employee timesheets selected for testing. The Organization appreciates the opportunity to strengthen the documentation of an existing supervisory review process to ensure approvals are consistently evidenced and retained. To address the recommendation, the Organization has reinforced supervisory expectations, updated internal procedures related to timesheet approvals, and implemented periodic monitoring to verify that supervisory approvals are consistently documented and retained. Management believes these enhancements appropriately address the recommendation and further strengthen the Organization's existing internal control environment while reinforcing its commitment to sound internal controls and compliance with applicable grant requirements.
Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Commissioner should constantly be aware of the possibility that errors or fraud could occur and contin...
Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, the management and Board of Commissioner should constantly be aware of the possibility that errors or fraud could occur and continue current practices mitigating these possibilities and examine and implement other mitigating controls when appropriate. Action Taken: The County has assessed the benefits and costs associated with proper segregation of duties and has determined that costs would outweigh the benefits received. The County understands the inherent risks associated with improper segregation of accounting functions. Management has communicated the need for transactions to be well supported by documentation as well as seeking appropriate authorization when appropriate. The County requires reporting to the Board of Commissioner for all disbursements to ensure transactions are proper and potential errors and irregularities are identified on a timely basis. The County will continue to review accounting procedures and processes to further mitigate this internal control deficiency whenever possible and feasible.
Finding 1221683 (2025-001)
Material Weakness 2025
Finding Number: 2025-001 Federal Programs: • ALN 93.696 – Certified Community Behavioral Health Clinic Expansion Grants (Grant No. H79SM087001-01) • ALN 93.788 – Opioid STR (Grant No. H79TI087831) Finding Title: Activities Allowed or Unallowed / Allowable Cost Principles Condition: During testing, i...
Finding Number: 2025-001 Federal Programs: • ALN 93.696 – Certified Community Behavioral Health Clinic Expansion Grants (Grant No. H79SM087001-01) • ALN 93.788 – Opioid STR (Grant No. H79TI087831) Finding Title: Activities Allowed or Unallowed / Allowable Cost Principles Condition: During testing, it was noted that payroll was allocated to the grants based on budget estimates because the payroll system used did not allow staff to document their hours across multiple programs in real-time. However, after-the-fact reviews of charges made to the Federal awards were not done to ensure that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Planned Corrective Action: HealthWest will update payroll procedures to perform after-the-fact reviews of payroll allocations charged to federal grants. As part of these reviews, management will compare each employee's budgeted grant allocation percentages to the employee’s Salary Allocation Schedule (SAL) and actual time worked on grant activities, as supported by available program and operational records. Any differences identified will be analyzed and appropriate payroll allocation adjustments will be made during the year-end review process to ensure final amounts charged to federal awards are accurate, allowable, and properly allocated. Anticipated Completion Date: September 30, 2026 Responsible Official: Brandy Carlson, Chief Financial Officer
Corrective Action Plan: Management acknowledges the deficiency. The City has historically performed suspension and debarment verification as part of its contract review process prior to contract execution; however, documentation evidencing completion of the verification was not retained in the contr...
Corrective Action Plan: Management acknowledges the deficiency. The City has historically performed suspension and debarment verification as part of its contract review process prior to contract execution; however, documentation evidencing completion of the verification was not retained in the contract file. To strengthen this control, the City has implemented procedures requiring documentation of suspension and debarment verification for all federally funded contracts and grant-related procurements. Staff will retain a dated screenshot or other evidence of the System for Award Management (SAM.gov) search in each applicable contract file prior to contract execution. Additionally, the City's Procurement Policy was updated and approved by the City Council in October 2025 to further strengthen procurement procedures and federal grant compliance requirements. Finance staff will periodically review contract files to verify that the required documentation has been retained. Personnel Responsible for Corrective Action: Nick Hawkins, Finance Manager Anticipated Completion Date: October 31, 2025
We will implement proper internal control procedures for the Housing choice Voucher VMS reconciliation process.
We will implement proper internal control procedures for the Housing choice Voucher VMS reconciliation process.
We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements
We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements
Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Krishonna Murray, Executive Director I. 2025-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verification. Gardner Housing Authorit...
Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Krishonna Murray, Executive Director I. 2025-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verification. Gardner Housing Authority has established a system of internal control over the participant recertification process that meets HUD's requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.
Finding Number: 2025-002 Finding Title: Cash Collateralization (Repeat Finding 2024-004) Planned Corrective Action: Management acknowledges the finding regarding cash collateralization. As of September 30, 2025, the Coalition's cash deposits were pledged and collateralized. After year-end, managemen...
Finding Number: 2025-002 Finding Title: Cash Collateralization (Repeat Finding 2024-004) Planned Corrective Action: Management acknowledges the finding regarding cash collateralization. As of September 30, 2025, the Coalition's cash deposits were pledged and collateralized. After year-end, management became aware that two affiliated financial institutions participating in the deposit sweep program had inadvertently assigned the same certificate numbers during the nightly sweep process. Consequently, a portion of the Coalition's deposits may have been swept into the same financial institution, resulting in balances that may have temporarily exceeded applicable FDIC insurance limits. Although this condition resulted from the financial institutions' sweep process rather than the Coalition's cash management practices, management recognizes its responsibility to monitor deposit coverage and ensure compliance. To address this finding, the Coalition will implement the following corrective actions: 1. Meet with representatives from both participating banks to discuss the issue and formally notify them of the audit finding. 2. Request written confirmation that the nightly sweep process has been reviewed and modified to prevent deposits from being placed with the same institution through duplicate certificate assignments or other system errors. This may happen from time-to-time but IntraFi corrects those deposits and reallocates them, It will be reviewed weekly to make sure they did reallocate those funds. 3. Communication with certain representatives within the financial institution will be contacted by NUHIC and will need to request that dollars are required to be transferred to IntraFi to remain in compliance of your audit before 2:30pm everyday. 4. Obtain and review periodic reports from the financial institutions identifying the banks holding swept deposits and the amount of funds placed with each institution. 5. Establish a weekly review process to monitor cash balances, FDIC insurance coverage, and collateralization to identify any exceptions on a timely basis. 6. Maintain documentation of all reviews, bank communications, and corrective actions as part of the Coalition's internal control procedures. 7. If the financial institutions cannot provide adequate assurance that deposits will remain fully insured or properly collateralized, the Coalition will evaluate alternative cash management options, including other insured cash sweep providers or collateralized deposit arrangements. Management believes these corrective actions will strengthen oversight of the Coalition's cash management process and reduce the risk of future noncompliance with FDIC insurance requirements. Responsible Official: Carlett Gregory Anticipated Completion Date: December 31, 2026
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