Corrective Action Plans

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Finding 1226199 (2024-002)
Material Weakness 2024
Management’s Response and Corrective Action Plan Management was unaware that certain City of Philadelphia contracts contained federal pass-through funding until confirmation was received from the City during the audit. Upon becoming aware of the federal funding, management developed an allocation me...
Management’s Response and Corrective Action Plan Management was unaware that certain City of Philadelphia contracts contained federal pass-through funding until confirmation was received from the City during the audit. Upon becoming aware of the federal funding, management developed an allocation methodology for shared personnel costs and has begun implementing procedures to identify federal funding at award inception and to document payroll allocations contemporaneously for future reporting periods.
The agency has created new policies and implemented fails saifs, including board involvement, to ensure the deadlines for all required filings are met.
The agency has created new policies and implemented fails saifs, including board involvement, to ensure the deadlines for all required filings are met.
As of the 24-25 fiscal year, the agency has created a sustainable cost allocation process that will be in place moving forward. New policies were created, including a system for analysis of allocations throughout the year.
As of the 24-25 fiscal year, the agency has created a sustainable cost allocation process that will be in place moving forward. New policies were created, including a system for analysis of allocations throughout the year.
Management will: Establish grant closeout deadlines based on project award defined end date, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.
Management will: Establish grant closeout deadlines based on project award defined end date, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.
Management will: Establish grant drawdown submission deadlines, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.
Management will: Establish grant drawdown submission deadlines, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Creation of a subset of general ledger codes for unallowed program costs, Management review of program expenditure requests prior to payment, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Creation of a subset of general ledger codes for unallowed program costs, Management review of program expenditure requests prior to payment, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Monthly review of program expenditures for overall grant period, Quarterly reconciliation of voided checks against program drawdown invoices, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Monthly review of program expenditures for overall grant period, Quarterly reconciliation of voided checks against program drawdown invoices, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Monthly reconciliation of payroll documentation with general ledger allocations, Monthly review of payroll allocation with program directors to ensure proper allocations, Quarterly review of payroll system to ensure pr...
Management will improve internal processes and controls to include the following: Monthly reconciliation of payroll documentation with general ledger allocations, Monthly review of payroll allocation with program directors to ensure proper allocations, Quarterly review of payroll system to ensure proper grant tracking functionally, Annual review with program directors of program requirements, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Monthly staff training for documentation retention requirements and policies, Quarterly audits of program expenditure documentation, and Annual Uniform Guidance compliance training.
Management will improve internal processes and controls to include the following: Monthly staff training for documentation retention requirements and policies, Quarterly audits of program expenditure documentation, and Annual Uniform Guidance compliance training.
Management’s Response: The Village has contracted a third-party consultant to help the management with implementation of policies that will ensure the timely financial reporting and ensuring the timely completion of the audit. The Village has now hired and has a complete Human Resource department an...
Management’s Response: The Village has contracted a third-party consultant to help the management with implementation of policies that will ensure the timely financial reporting and ensuring the timely completion of the audit. The Village has now hired and has a complete Human Resource department and Finance department that has been in place for a year now. The Village has contracted a third-party accounting firm to facilitate with the training and processes required to completing year-end closing. Responsible Party: Mayte Gamiotea, Chief Financial Officer Anticipated Completion Date: September 30, 2026
Finding Summary: The Entity does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards (the schedule) being audited. We requested our auditors to assist with the preparation of the schedule and accompanying notes to the schedul...
Finding Summary: The Entity does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards (the schedule) being audited. We requested our auditors to assist with the preparation of the schedule and accompanying notes to the schedule. Responsible Individuals: Craig Arnold, Chief Executive Officer Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards. We requested that our auditors, Eide Bailly LLP, prepare the schedule as a part of the program-specific audit. We have designated a member of management to review the schedule. Anticipated Completion Date: Ongoing.
2024-001 – Data Collection Forms Finding: Our audit procedures noted Champlain Fire District did not certify or submit the required Data Collection Form for the fiscal year ended December 31, 2024 related to the 2024 Single Audit. As of the date of our 2024 audit, the Data Collection Form and accomp...
2024-001 – Data Collection Forms Finding: Our audit procedures noted Champlain Fire District did not certify or submit the required Data Collection Form for the fiscal year ended December 31, 2024 related to the 2024 Single Audit. As of the date of our 2024 audit, the Data Collection Form and accompanying reporting package remain unsubmitted. Recommendation: We recommend that the Fire District implement procedures to ensure the timely preparation, certification, and submission of the annual Data Collection Form and reporting package when federal funds are received. This should include assigning responsibility for tracking deadlines, establishing a completion checklist, and documenting management review prior to submission. Action Taken: Champlain Fire District agrees with the finding and will implement procedures to address the recommendation in 2025.
Finding #2024-002 – Material Weakness – Activities Allowed or Unallowed, Allowable Cost Principles 93.667 Social Services Block Grant - HAP - Bridge Housing and Case Management Payroll Approval Condition During our audit of the Organization for compliance with Uniform Guidance requirements, we noted...
Finding #2024-002 – Material Weakness – Activities Allowed or Unallowed, Allowable Cost Principles 93.667 Social Services Block Grant - HAP - Bridge Housing and Case Management Payroll Approval Condition During our audit of the Organization for compliance with Uniform Guidance requirements, we noted that the client was unable to provide sufficient evidence that the amount being requested for reimbursement was based on actual effort of employees during reimbursement period. In total 40 payroll samples were selected for testing and the lack of support for time spent by employees occurred for all items tested. Recommendation We recommend that Organization establish and enforce formal procedures requiring documented management review and approval of all payroll transactions including review of employees level of effort before they are processed. The review process should be supported by evidence, such as approval signatures, electronic audit trails, or other verifiable records. In addition, management should perform regular reconciliations of payroll to ensure compliance with federal and organizational policies. Management’s Corrective Action Plan Management concurs with this finding. During the fiscal year, the Organization experienced significant turnover within the Accounting and Finance Department, which impacted the consistent execution nd documentation of established payroll review and approval procedures. Although payroll was reviewed prior to processing, management acknowledges that documentation evidencing the review and approval was not consistently maintained to demonstrate compliance with internal control requirements. The Organization recognizes the importance of documented management review as a key internal control over payroll expenditures, particularly for ensuring the appropriate stewardship of federal funds. To address this finding, management has implemented the following corrective actions:  Formalized written payroll processing procedures that require documented review and approval of each payroll register prior to transmission for processing.  Established a standardized payroll approval checklist to document management’s review of payroll changes, employee additions and terminations, pay rate changes, deductions, and payroll totals before each payroll is processed.  Clearly defined segregation of duties between Human Resources, Payroll, and Finance to ensure appropriate authorization and oversight throughout the payroll process.  Implemented a centralized electronic retention process for payroll registers, approval documentation, and supporting reports to ensure records are complete and readily available for audit.  Conducted training with Human Resources and Finance personnel on payroll approval requirements and documentation standards.  Included periodic supervisory reviews of payroll documentation as part of the Finance Department’s internal monitoring process to ensure ongoing compliance. Management believes these corrective actions have strengthened internal controls over payroll processing and approval and will ensure that payroll transactions are consistently reviewed, approved, and appropriately documented prior to payment. Contact Person: Kathy Desmond, President and CEO Anticipated Completion Date: June 30, 2025
Finding #2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2024, management was unable to provide timely year-end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect...
Finding #2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2024, management was unable to provide timely year-end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect the underlying accounting transactions. Recommendation We recommend that individuals overseeing the accounting and finance function continue to review the Organization's current accounting policies and update existing policies or implement new policies, as necessary, to ensure that accounting records are accurately maintained throughout the year. In addition, we recommend the Organization develop and document formal year-end closing procedures, including detailed closing checklists, assignment of responsibilities, and timelines for the preparation and review of reconciliations, trial balances, and supporting schedules. Monthly and quarterly account reconciliations, as appropriate, should be completed and reviewed timely throughout the year to facilitate an efficient year-end close process and ensure that complete and accurate trial balances and related supporting documentation are prepared and reviewed on a timely basis after year-end. Management’s Corrective Action Plan Management concurs with this finding. The delays in maintaining timely accounting records, completing reconciliations, and preparing year-end financial statements were primarily the result of significant turnover within the Accounting and Finance Department during the fiscal year, combined with the operational demands associated with the merger of HopePHL and Youth Service, Inc. These circumstances created a backlog of transaction processing and account reconciliations that ultimately delayed the preparation of accurate trial balances and required yearend adjustments to ensure compliance with U.S. GAAP. Since the conclusion of the audit period, management has implemented several corrective actions to strengthen the organization’s financial reporting processes and internal controls. These actions include:  Rebuilding and stabilizing the Accounting and Finance Department through the recruitment and retention of qualified personnel.  Establishing defined month-end closing procedures, including assigned responsibilities and timelines for completing reconciliations and reviewing financial activity.  Implementing a monthly close calendar with management oversight to ensure timely completion of accounting tasks and identification of outstanding issues.  Strengthening supervisory review of account reconciliations, journal entries, and financial reporting to improve the accuracy and completeness of accounting records throughout the year.  Monitoring compliance with financial reporting deadlines through regular meetings between Finance leadership and executive management. Management believes these corrective actions have substantially addressed the conditions that led to this finding and will help ensure that accounting records are maintained in accordance with U.S. GAAP, financial statements are prepared on a timely basis, and future reporting requirements, including those under 2 CFR §200.512(a)(1), are met. Contact Person: Kathy Desmond, President and CEO Anticipated Completion Date: June 30, 2025
Management has implemented procedures to identify all federal awards and reconcile to general ledger before preparing the SEFA.
Management has implemented procedures to identify all federal awards and reconcile to general ledger before preparing the SEFA.
Finding 2024-001, Cash Disbursement Policy Recommendation We recommend the organization follow the documented cash disbursement process and ensure reviews and approvals are documented. Response NEFHS self-identified such inconsistencies through its normal internal control process and implemented a P...
Finding 2024-001, Cash Disbursement Policy Recommendation We recommend the organization follow the documented cash disbursement process and ensure reviews and approvals are documented. Response NEFHS self-identified such inconsistencies through its normal internal control process and implemented a Payable Invoice Management (PIM} system in November 2023. With the loss of personnel this system became too cumbersome and inefficient. All invoices were eventually approved by management with the final approval coming from the CEO when signed. NEFHS has moved to a new financial software platform with an integrated accounts payable system. All invoices are approved for payment before checks are cut and distributed.
Finding Number 2024-016 (Repeat 2023-018) Corrective Action Plan Procurement, Suspension and Debarment — AL 93.323 (U.S. Department of Health and Human Services) • Formalize into established written policies and procedures the monitoring of the suspension and debarment status of vendors and contract...
Finding Number 2024-016 (Repeat 2023-018) Corrective Action Plan Procurement, Suspension and Debarment — AL 93.323 (U.S. Department of Health and Human Services) • Formalize into established written policies and procedures the monitoring of the suspension and debarment status of vendors and contractors, designed on the verification methods provided in 2 CFR § 180.300 — checking SAM.gov, collecting a certification, or including a clause in the covered transaction. • Continue performing suspension and debarment verification checks prior to entering into covered transactions as part of the standard procurement checklist, and retain documentary evidence of each check in the procurement file. • Continue to guide and make aware the compliance team and all departments of the requirement, and include it in procurement staff training. • Perform periodic compliance testing of the checklist and the retained evidence, with exceptions reported to management for corrective action. • Pursue resolution of the questioned costs of $509,463 through the audit resolution process with the grantor agency. Management’s position is that the condition is an internal control deficiency and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as the entire population comprises allowable transactions and verification against the SAM.gov exclusions list confirmed that no vendor or contractor was suspended, debarred or otherwise excluded. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Mr. Happyman Makamure Email: happyman.makamure@dofa.gov.fm
Finding Number 2024-015 (Repeat 2023-017) Corrective Action Plan Equipment and Real Property Management — AL 93.323 (U.S. Department of Health and Human Services) • Rebuild the Fixed Asset Register so that it captures the property record data elements required by 2 CFR § 200.313(d)(1) —description, ...
Finding Number 2024-015 (Repeat 2023-017) Corrective Action Plan Equipment and Real Property Management — AL 93.323 (U.S. Department of Health and Human Services) • Rebuild the Fixed Asset Register so that it captures the property record data elements required by 2 CFR § 200.313(d)(1) —description, serial or other identification number, source of funding including the Federal award identification number, title holder, acquisition date and cost, percentage of Federal contribution, and the location, use and condition of each asset, together with any disposition data. • Complete the rebuild well ahead of the FY2025 audit for migration into the fixed asset register module of the new FMIS (FreeBalance), with the funding source of each asset identified. • Conduct physical checks and counts of assets following the rebuild, including locating and confirming the status and condition of the assets identified in this finding, so that adjustments — including deletions and other corrections — are recorded for FY2025 and appropriate action is taken on assets found to be missing, broken, or requiring repair or disposition. • Establish, issue and enforce a written policy with comprehensive procedures covering effective safeguards against loss, damage or theft of property, together with maintenance protocols to keep property in good condition, in line with 2 CFR §§ 200.313(d)(3) and (d)(4). • Continue advice, guidance and training to the Supply Team on the recording, tracking, reconciliation, safeguarding and maintenance of capital assets. • Pursue resolution of the questioned costs of $19,824 through the audit resolution process with the grantor agency upon completion of the physical verification. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Melynda Irons Acting Assistant Secretary, Treasury Email: melynda.irons@dofa.gov.fm Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Mr. Lester Sackryas Supply Manager Email: lester.sackryas@dofa.gov.fm
Finding Number 2024-014 (Repeat 2023-010) Corrective Action Plan Special Tests and Provisions — Annual Performance Reviews — AL 15.875 (U.S. Department of the Interior) • Continue and complete the annual performance evaluations, commenced in 2025, for all personnel funded under the Education Sector ...
Finding Number 2024-014 (Repeat 2023-010) Corrective Action Plan Special Tests and Provisions — Annual Performance Reviews — AL 15.875 (U.S. Department of the Interior) • Continue and complete the annual performance evaluations, commenced in 2025, for all personnel funded under the Education Sector Grant and the Supplemental Education Grant, and maintain the completed evaluations in the personnel files, available for grant oversight and audit purposes. • Obtain and maintain a complete listing of all SEG and Education Sector funded personnel, reconciled to payroll, as the basis for scheduling the required evaluations. • Establish written monitoring procedures, including a schedule of evaluations due and periodic status reporting, to ensure that funded personnel are evaluated on an annual basis. • Assign a dedicated employee to monitor compliance with the requirement and perform the required procedures, in line with the auditors’ recommendation. • Include the requirement in the compliance team’s periodic compliance checks and in the orientation of program and departmental staff. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) FSM Department of Education [Contact details to be provided]
Finding Number 2024-013 (Repeat 2023-009) Corrective Action Plan Subrecipient Monitoring — AL 15.875 (U.S. Department of the Interior) • Establish and formally document the subrecipient monitoring framework, policies and procedures, aligned to the pass-through entity requirements of the Uniform Guid...
Finding Number 2024-013 (Repeat 2023-009) Corrective Action Plan Subrecipient Monitoring — AL 15.875 (U.S. Department of the Interior) • Establish and formally document the subrecipient monitoring framework, policies and procedures, aligned to the pass-through entity requirements of the Uniform Guidance and to the classification agreed with DOI, for implementation from the effective date agreed with DOI/OIA. • Update the annual subrecipient agreement transmitted to the FSM State Governments and signed by the President and the Governors as allottees, facilitated by the Office of Compact Management, to expressly incorporate the clauses required by the 2023 Amended Compact, the identification of the subaward, and acknowledgement of the requirements imposed on the sub-grantees. • Perform and document, prior to approval of each subaward, verification of the sub-grantee’s awareness of the requirements imposed upon it and its ability to meet the financial management standards of the Fiscal Procedures Agreement. • Perform and document an annual risk assessment of each subrecipient, together with the resulting monitoring activities, including review of the subrecipients’ audit reports and follow-up on findings affecting the program. • Maintain records of the date of receipt and date of disbursement of funds to the FSM State Governments, evidencing that disbursements are made within the month of receipt through the required wire-out approval process. • Pursue resolution of the questioned costs of $94,422,154 through the audit resolution process with DOI/OIA. Management’s position is that the conditions are internal control deficiencies arising from the absence of formally documented policies and procedures and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as all samples were provided, vouched and cleared, and the amounts represent Compact sector grant allocations approved through JEMCO. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Melynda Irons Acting Assistant Secretary, Treasury Email: melynda.irons@dofa.gov.fm Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm
Finding Number 2024-012 (Repeat 2023-011) Corrective Action Plan Reporting — AL 15.875 (U.S. Department of the Interior) • Establish a reporting calendar identifying each SF-425 due date, and issue a formal request and follow-up protocol to the FSM State Governments requiring submission of their qua...
Finding Number 2024-012 (Repeat 2023-011) Corrective Action Plan Reporting — AL 15.875 (U.S. Department of the Interior) • Establish a reporting calendar identifying each SF-425 due date, and issue a formal request and follow-up protocol to the FSM State Governments requiring submission of their quarterly reports sufficiently in advance of the consolidated due date. • Designate a responsible officer to compile the consolidated SF-425, reconcile it to the accounting records, and obtain documented supervisory review before submission to OIA by the applicable due date. • Where a state report remains outstanding at the due date, submit the SF-425 on the basis of the best available data by the due date and file a revised report upon receipt of the outstanding submission, documenting the communication with OIA. • Escalate persistent non-submission by a state to the Office of Compact Management and address it through the subrecipient agreement and the subrecipient monitoring framework being established under Finding 2024-013. • Maintain a file of all reports submitted together with the supporting reconciliations for grant oversight and audit purposes. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm
Finding Number 2024-011 (Repeat 2023-007) Corrective Action Plan Equipment and Real Property Management — AL 15.875 (U.S. Department of the Interior) • Rebuild the Fixed Asset Register so that it captures the property record data elements required by Article VI, Section 1(f)(vi)(a) of the Fiscal Pro...
Finding Number 2024-011 (Repeat 2023-007) Corrective Action Plan Equipment and Real Property Management — AL 15.875 (U.S. Department of the Interior) • Rebuild the Fixed Asset Register so that it captures the property record data elements required by Article VI, Section 1(f)(vi)(a) of the Fiscal Procedures Agreement — description, serial or other identification number, source of the property, title holder, acquisition date and cost, percentage of grant funds used in the purchase, and the location, use and condition of each asset. • Identify within the register the capital assets procured with federal funding under the program, so that assets attributable to the award can be readily determined and audit sample selection supported. • Maintain a schedule of disposals, including the date of disposal and the sale price of each asset disposed of, and produce it for audit. • Complete the rebuild well ahead of the FY2025 audit for migration into the fixed asset register module of the new FMIS (FreeBalance), with the funding source of each asset identified so the system-based register carries complete records from the outset. • Conduct physical checks and counts of assets following the rebuild, with adjustments including deletions and other corrections recorded for FY2025 and continue guidance to the Supply Team on the FPA property record requirements. • Pursue resolution of the questioned costs (undeterminable) through the audit resolution process with DOI/OIA on completion of the rebuilt register. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Melynda Irons Acting Assistant Secretary, Treasury Email: melynda.irons@dofa.gov.fm Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Mr. Lester Sackryas Supply Manager Email: lester.sackryas@dofa.gov.fm
Finding Number 2024-010 Corrective Action Plan Cash Management — AL 15.875 (U.S. Department of the Interior) • Develop, approve and issue a dedicated written cash management procedure specifically addressing the time elapsing between the receipt of infrastructure project funds and their disbursement...
Finding Number 2024-010 Corrective Action Plan Cash Management — AL 15.875 (U.S. Department of the Interior) • Develop, approve and issue a dedicated written cash management procedure specifically addressing the time elapsing between the receipt of infrastructure project funds and their disbursement, setting out the disbursement process and target timeframes consistent with Article IV, Section 5(b)(ii) of the Fiscal Procedures Agreement. • Maintain documentation of the date of receipt and the date of disbursement for each drawdown, so that compliance with the procedure and the minimization of elapsed time can be evidenced and monitored. • Institute periodic monitoring and reporting of elapsed time between receipt and disbursement, with exceptions escalated for management action. • Train Treasury staff and the authorized signatories in the wire-out approval process on the new procedure and the applicable FPA requirement. • Pursue resolution of the questioned costs of $1,643,137 through the audit resolution process with DOI/OIA. Management’s position is that the condition is an internal control deficiency and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as the FPA prescribes no day-count standard, all disbursements were made within the month of receipt through the required approval process, and the payments were eligible, fully supported and reasonable. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm
We acknowledge and concur with the auditor’s finding. Management will establish a formal process to track Uniform Guidance and Federal Audit Clearinghouse reporting deadlines to ensure that future reporting packages and data collection forms are completed and submitted within the required timeframe....
We acknowledge and concur with the auditor’s finding. Management will establish a formal process to track Uniform Guidance and Federal Audit Clearinghouse reporting deadlines to ensure that future reporting packages and data collection forms are completed and submitted within the required timeframe. Contact Person Responsible for Corrective Action: Doug Williams Anticipated Completion Date: September 1, 2026
We acknowledge and concur with the auditor’s finding. Management will strengthen its controls over grant expenditure reporting to ensure that expenditure reports submitted to grantors reflect only expenditures actually incurred during the reporting period. Construction costs will be reported when th...
We acknowledge and concur with the auditor’s finding. Management will strengthen its controls over grant expenditure reporting to ensure that expenditure reports submitted to grantors reflect only expenditures actually incurred during the reporting period. Construction costs will be reported when the related work is performed and costs are incurred, rather than when contracts are executed, and expenditures will be reviewed for allowability under the applicable grant agreement before inclusion in a report. All expenditure reports will be reconciled to the accounting records and independently reviewed and approved prior to submission to the grantor. Contact Person Responsible for Corrective Action: Doug Williams Anticipated Completion Date: September 1, 2026
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