Corrective Action Plans

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DCH is implementing a comprehensive risk analysis framework utilizing the ServiceNow GRC module. This framework will systematically assess risks across all relevant systems and evaluate the effectiveness of existing controls in mitigating identified risks. While DCH has historically obtained and le...
DCH is implementing a comprehensive risk analysis framework utilizing the ServiceNow GRC module. This framework will systematically assess risks across all relevant systems and evaluate the effectiveness of existing controls in mitigating identified risks. While DCH has historically obtained and leveraged independent security assessments—including SOC Type II reports, Security Assessment Reports, and HITRUST validations—to inform its security posture, we recognize the need for enhanced documentation and a formalized assessment process. To address this finding, DCH has taken the following corrective actions: • Standardized Documentation Procedures: Implemented a formalized process to document the receipt, review, and analysis of SOC Type II reports, Complementary User Entity Controls (CUECs), and other relevant security assessments. • Automated Assessment Framework: Leveraging the ServiceNow GRC module to establish a structured, repeatable process for evaluating the effectiveness of implemented controls and their role in mitigating identified risks. • Training & Process Integration: Conducted staff training on the importance of documentation and the new assessment framework to ensure consistent execution and compliance. We remain committed to strengthening our security posture and refining our processes to enhance compliance and risk management. While the SSP approval occurred outside the audit period, DCH has since ensured that approved SSPs for critical Medicaid systems—including Georgia Medicaid Management Information System (GAMMIS), Gateway, and the Enterprise Analytics Solution for Everyone (EASE) are in place. DCH has already begun implementing these corrective actions and anticipates full implementation by April 30, 2025
At the end of the Low Income Home Energy Assistance Program (LIHEAP) season, the State Program Office and other applicable areas such as Grant Administration, Office of Information Technology, etc. (Team) will attend the annual training completed by the Office of Community Services (OCS). The OCS Ho...
At the end of the Low Income Home Energy Assistance Program (LIHEAP) season, the State Program Office and other applicable areas such as Grant Administration, Office of Information Technology, etc. (Team) will attend the annual training completed by the Office of Community Services (OCS). The OCS Household Report training is typically scheduled in November of each year. After the training session, the team will discuss any changes to the new Household Report. The State Program Office will contact the Georgia Environmental Finance Authority (GEFA) to request information about their annual household report. The Household Report will be printed from the Online Data Collection (OLDC) system for review, discussion, and completion by the team, usually around the middle of December to finalize the draft report. Upon completion of the review and approval by the necessary areas, the State Program Office will submit the Household Report to OLDC for approval and acceptance.
The Office of Procurement Services (OPS) has dedicated staff that have attended Federal Funding Accountability and Transparency Act (FFATA) training and webinars. In addition, the same dedicated staff will verify that all federal grants with sub-recipients are properly reported. Beginning in FY 202...
The Office of Procurement Services (OPS) has dedicated staff that have attended Federal Funding Accountability and Transparency Act (FFATA) training and webinars. In addition, the same dedicated staff will verify that all federal grants with sub-recipients are properly reported. Beginning in FY 2025 (September 2024), the OPS has required programs that receive federal funding to email a PDF copy of the monthly FFATA report submitted in the FFATA Subaward Reporting System (FSRS) to the designated staff no later than the fifth of each month. Currently, the FY25 FFATA Reporting is up to date and the Office of Procurement Services will continue to review and adjust the process through FY 2025 (June 30, 2025).
The monthly student reconciliations for the Direct Loan programs, including the SAS files, have resumed starting with the October 2024 SAS file. These reconciliations will continue on a monthly basis by the financial aid office, as required, and will be conducted without interruption. The reconcilia...
The monthly student reconciliations for the Direct Loan programs, including the SAS files, have resumed starting with the October 2024 SAS file. These reconciliations will continue on a monthly basis by the financial aid office, as required, and will be conducted without interruption. The reconciliation process will be closely monitored, reviewed, and approved monthly by management to ensure ongoing compliance. The loan processing team has been trained on the SAS file import process and direct loan reconciliation. They have also been provided with the necessary system resources to identify variances between Common Origination and Disbursement (COD) and Banner at the student level. Additionally, the direct loan reconciliation process documentation will undergo continuous review and monitoring by the loan processing team, with oversight from the Director of Student Financial Aid and Scholarships, to ensure accuracy and adherence to established policies with each new academic year. The loan processing team will have annual refresher training at the beginning of each academic year. Confirmation of employees, date of training, and current training process will be documented.
On July 29, 2024, Georgia State University (GSU) was made aware of a National Student Loan Data System (NSLDS) reporting defect in our student information system related to program level reporting. A system correction was installed on November 25, 2024. GSU will enhance monitoring procedures to ensu...
On July 29, 2024, Georgia State University (GSU) was made aware of a National Student Loan Data System (NSLDS) reporting defect in our student information system related to program level reporting. A system correction was installed on November 25, 2024. GSU will enhance monitoring procedures to ensure discrepancies in reporting to the NSLDS are identified and corrected in a timely manner.
The student in question had a lengthy break in enrollment (2015-2024). When the student returned, CGTC’s Banner rules differed from his previous enrollment and his status was not accurately updated within the correct term. To correct the issue, CGTC has worked with colleagues at the Technical Coll...
The student in question had a lengthy break in enrollment (2015-2024). When the student returned, CGTC’s Banner rules differed from his previous enrollment and his status was not accurately updated within the correct term. To correct the issue, CGTC has worked with colleagues at the Technical College System of Georgia to identify and correct any discrepancies in the Banner rules for the Satisfactory Academic Progress (SAP) process to prevent future occurrences of this issue. The College’s Financial Aid office has identified the “cutoff” year for changes in SAP rules and has developed a procedure to manually review any students with long breaks in enrollment whose last enrollment occurred prior to the identified cutoff. This review process will help to ensure that students’ SAP status is accurately updated in the correct term.
View Audit 354902 Questioned Costs: $1
The Financial Aid Office has worked with the Registrar's Office to streamline the collection, review and processing of student who are unofficial withdrawals. Streamlining the unofficial withdrawal process will allow for timely and accurate reporting, return to title IV, and reconciliation of funds ...
The Financial Aid Office has worked with the Registrar's Office to streamline the collection, review and processing of student who are unofficial withdrawals. Streamlining the unofficial withdrawal process will allow for timely and accurate reporting, return to title IV, and reconciliation of funds between Lanier Technical College and Common Origination and Disbursement (COD).
View Audit 354902 Questioned Costs: $1
The University of Georgia acknowledges the need for increased monitoring over the return to Title IV aid for students withdrawn from the University. UGA has taken immediate corrective action and has filled key staffing vacancies and implemented additional internal controls to monitor and ensure comp...
The University of Georgia acknowledges the need for increased monitoring over the return to Title IV aid for students withdrawn from the University. UGA has taken immediate corrective action and has filled key staffing vacancies and implemented additional internal controls to monitor and ensure compliance. A self-audit of Fall 2024 revealed no non-compliance issues.
To prevent future errors, staff will undergo training to ensure accurate processing of withdrawals that occur after the term has ended. Both official and unofficial withdrawals will be evaluated based on the student's last date of attendance when the withdrawal date is after the end of term. While...
To prevent future errors, staff will undergo training to ensure accurate processing of withdrawals that occur after the term has ended. Both official and unofficial withdrawals will be evaluated based on the student's last date of attendance when the withdrawal date is after the end of term. While the Financial Aid Office (FAO) staff have adhered to the current withdrawal procedures, we recognize the need for an update to address instances when the date a student initiates the official withdrawal process is earlier than when the withdrawal is completed. To address this, we will adopt the date the student begins the withdrawal process as the official withdrawal date, if this date precedes the completion of the withdrawal form. Additionally, we will implement automated and electronic system controls to ensure withdrawals are processed accurately and within the required timelines by monitoring the full withdrawal cycle. The withdrawal policy and administrative procedures documentation will be updated to reflect these changes. Staff will have annual refresher training at the beginning of each academic year. Confirmation of employees, date of training, and training process will be documented.
View Audit 354902 Questioned Costs: $1
Georgia State University (GSU) will ensure all team members are appropriately trained related to the return to title IV process. Procedures have been enhanced to ensure that unearned funds required to be returned to the program due to return to title IV calculations are immediately reconciled and re...
Georgia State University (GSU) will ensure all team members are appropriately trained related to the return to title IV process. Procedures have been enhanced to ensure that unearned funds required to be returned to the program due to return to title IV calculations are immediately reconciled and returned during the required window. GSU has established an Assistant Director over Electronic Processing to carry out these procedures.
Georgia State University (GSU) will ensure all team members are appropriately trained related to the process for locking student financial aid records and completing verifications after the term ends. Additionally, GSU has enhanced monitoring procedures to identify changes to institutional student i...
Georgia State University (GSU) will ensure all team members are appropriately trained related to the process for locking student financial aid records and completing verifications after the term ends. Additionally, GSU has enhanced monitoring procedures to identify changes to institutional student information records after term ends with a verification indicator to ensure these accounts are resolved in a timely manner.
View Audit 354902 Questioned Costs: $1
Beginning in FY2025, the Department of Human Services (DHS) Office of Procurement Services (OPS) began reviewing new contracts in the new contracting system, Contract Lifecycle Management (CLM) System for compliance with State Procurement Rules and Regulations. In addition, OPS will extend the revie...
Beginning in FY2025, the Department of Human Services (DHS) Office of Procurement Services (OPS) began reviewing new contracts in the new contracting system, Contract Lifecycle Management (CLM) System for compliance with State Procurement Rules and Regulations. In addition, OPS will extend the review to include all contract requests (new, amendments, extensions, and renewals). During the additional review, OPS will inform the program of any requests that are not in compliance with the Procurement Rules and Regulations before the contract is fully executed. OPS also reviewed prior contractual amendments, extensions, and renewals within the CLM System at the requisition level for compliance with the State Procurement Rules and Regulations. If an infraction was found, the program was notified and informed of the State Procurement Rules and Regulations.
Effective November 16, 2024, GDOL restructured the Benefit Accuracy Measurement (BAM) unit to strengthen internal controls by incorporating a secondary review process prior to the final review by the supervisor. This process allows the reconciliation of discrepancies and validates the accuracy of th...
Effective November 16, 2024, GDOL restructured the Benefit Accuracy Measurement (BAM) unit to strengthen internal controls by incorporating a secondary review process prior to the final review by the supervisor. This process allows the reconciliation of discrepancies and validates the accuracy of the case findings prior to the supervisory review. If the reviewer identifies questionable items during the review, the case is returned to the auditor for corrections and updates. Once completed, it is returned back to the reviewer for an additional review, sign-off, and then submission to the supervisor for review and closure. Beginning April 2025, an initiative will be implemented to train staff to perform quality checks. Staff will review a sample of cases completed by other auditors in the previous quarter and provide feedback. This plan is being established to posture staff to supplement gaps in resources if the need arises and address challenges, such as, attrition. This allows staff to effectively fulfill the responsibility of reviewing cases and preparing them for official signoff in a timely manner. Summary: GDOL greatly appreciates the feedback and recommendations and has and will continue to take appropriate measures to ensure the established BAM procedures are followed.
GDOL Response: GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response. GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment recor...
GDOL Response: GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response. GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. A cross match cannot be assumed to be an overpayment. GDOL must investigate cross matches and provide due process to all parties. GDOL developed an aggressive plan to complete all crossmatches. As of June 2024, GDOL was caught up and resume our regular crossmatch schedule. The current unemployment system is aged and distressed. GDOL’s limited technology resources will hinder our ability to update our current system to perform reconciliation between the multiple tools used to perform different functions. Therefore, we acknowledge that this finding may persist until a system-wide resolution is implemented in the new modernized UI system. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing merit and time-limited staff to maximize productivity by conducting fact-finding interviews, assessing case details, creating overpayments in the system, and making overpayment determinations. The statutes provide that an overpayment be established up to four years after such occurrence, act, or omission. Additionally, GDOL has procured a vendor to build and implement a modernized UI system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Throughout CY 2024, GDOL participated in quarterly meetings with United States Department of Labor (USDOL) and other regional states to discuss fraud, overpayment issues and best practices used. These meetings will continue in CY2025. Summary: GDOL greatly appreciates the feedback and recommendations and will ensure these and USDOL’s recommendations are incorporated into our new modernized system which is expected to be implemented in the Spring 2026.
After the September 2023 quarter, controls were put in place to ensure accurate Federal quarterly reports. These controls included preparing the report based on our accounting records, e.g. the general ledger. Another control is that the Chief Financial Officer or her designee reviews all reports an...
After the September 2023 quarter, controls were put in place to ensure accurate Federal quarterly reports. These controls included preparing the report based on our accounting records, e.g. the general ledger. Another control is that the Chief Financial Officer or her designee reviews all reports and compares them to the general ledger prior to signature, approval and our submission to the grantor. Furthermore, periodic reviews by program fiscal staff during the performance period take place to closely monitor activity. GDOL will continue to follow the updated procedures and internal controls. As we transition to GA@Work, the system itself will control overspending and provide alerts.
GDOL Response: GDOL acknowledges this is a repeated finding from previous years and is partially resolved, therefore the Department concurs with this finding and offers the following response. GDOL’s limited technology resources and funding will hinder our ability to update our current system to s...
GDOL Response: GDOL acknowledges this is a repeated finding from previous years and is partially resolved, therefore the Department concurs with this finding and offers the following response. GDOL’s limited technology resources and funding will hinder our ability to update our current system to satisfy the state audit’s recommendation. Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL will include a self-certification and dual certification process for employer-filed claims in the new solution. GDOL will also secure data analytic tools to aid GDOL staff with the identification of potential improper or fraudulent Payments, which will include payments linked to employer filed claims.
GDOL Response: GDOL acknowledges this is a repeated finding from previous years and is partially resolved, therefore the Department concurs with this finding and offers the following response. GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe “legacy’ te...
GDOL Response: GDOL acknowledges this is a repeated finding from previous years and is partially resolved, therefore the Department concurs with this finding and offers the following response. GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe “legacy’ technology. Due to the system’s age and other limitations, many automated processes and corrections cannot be fixed and/or easily implemented. As such, many processes must be handled manually by staff. This includes reviewing all the Pandemic Unemployment Assistance (PUA) proof documents submitted to determine the validity and eligibility for each PUA claim. Based on the volume of workload and staff limitations, GDOL has been unable to quickly complete this manual review to correct the finding. It is anticipated this manual review will continue throughout the FY25 audit review period. The modernized UI system will include controls over eligibility determination for current and future unemployment programs. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. We recognize the state auditor's recommendations to add the self-certification. However, the current unemployment system is aged and distressed. GDOL’s limited technology resources will hinder our ability to update our current system to satisfy the state audit’s recommendation. Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL will include a self-certification process for employer-filed claims in the new solution. GDOL has procured a vendor to build and implement a modernized UI system. We are also pursuing data analytics tools to expedite the identification and detection of fraudulent activities. These tools will also be incorporated into the modernized solution. Summary: GDOL greatly appreciates the feedback and recommendations and will ensure they are incorporated into the new UI modernized system which is planned to be implemented in Spring 2026.
View Audit 354902 Questioned Costs: $1
Federal Financial Report (FFR) processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the Criminal Justice Coordinating Council (CJCC) Budget Team. • Because the US DOJ Just Grants system does not allow for review or secon...
Federal Financial Report (FFR) processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the Criminal Justice Coordinating Council (CJCC) Budget Team. • Because the US DOJ Just Grants system does not allow for review or secondary viewers in the financial reporting system, the FFRs are to be saved digitally by the completing analyst/director. • FFRs will be reviewed with written certification of review by a budget team member that was not responsible for the primary submission of the report for each grant. • Any corrections will be made within the period of correction for the report to prevent a misstated report from becoming permanent record. Performance Measures Tool (PMT) processes are updated as follows: • Implemented a PMT data review and approval process that leverages Microsoft Planner to send messages to those involved and track the completion of review and approval by the manager. Prepared Federal Funding Accountability and Transparency Act (FFATA) reports processes are updated as follows: • FFATA Subrecipient Reporting is reviewed and approved by the Director of Grant Operations and submitted by the Grant Operations/Compliance Unit Staff to FSRS based upon the established reporting calendar.
We have prepared procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting specifically for USDA. We shifted a current GaDOE accounting manager's job duties to include assisting the Assistant Director of Accounting with overall FFATA reporting duties. The addition of an ex...
We have prepared procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting specifically for USDA. We shifted a current GaDOE accounting manager's job duties to include assisting the Assistant Director of Accounting with overall FFATA reporting duties. The addition of an experienced staff member to assist with FFATA data gathering, reconciling, and reporting will allow for the Assistant Director of Accounting to focus on completing the more complex FFATA Reporting for USDA in a timely manner.
Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional traini...
Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION Management is responsible for designing and maintaining internal controls over financial reporting that is sufficient to provide reasonable assurance that management can prepare the financial statement and the Uniform Guidance Audit Report...
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION Management is responsible for designing and maintaining internal controls over financial reporting that is sufficient to provide reasonable assurance that management can prepare the financial statement and the Uniform Guidance Audit Report in conformity with US GAAP and federal regulations. Management will improve accounting and financial reporting policies and procedures to include the timely issuance of the financial statement and the uniform guidance report. IMPLEMENTATION DATE March 31, 2026 RESPONSIBLE PERSON Paola Rosario CPA, CFO
Finding 556197 (2024-001)
Significant Deficiency 2024
Action(s) taken or planned on the finding: A transfer was made to fully fund the reserve for replacements account on March 6, 2025.
Action(s) taken or planned on the finding: A transfer was made to fully fund the reserve for replacements account on March 6, 2025.
View Audit 354882 Questioned Costs: $1
Friday, April 11, 2025 Dear Sir(s): CORRECTIVE ACTION PLAN In prior years the accounting of Pyramid Learning Corp. was executed externally by a contracted accounting company. During the year ended June 30, 2024 we acquired a specialized accounting software. After the acquisition of the new software,...
Friday, April 11, 2025 Dear Sir(s): CORRECTIVE ACTION PLAN In prior years the accounting of Pyramid Learning Corp. was executed externally by a contracted accounting company. During the year ended June 30, 2024 we acquired a specialized accounting software. After the acquisition of the new software, we recorded the data from the beginning of the year to the present, which required significant staff effort and made it impossible to maintain accounting and financial reports on a month-to-month basis. At the present, the data is already being recorded, and the accounting is up to dates. This allows us to keep our accounting and interim financial reports such as Balance Sheet, Statement of Activities, Bank Reconciliations, and monthly analysis of accounts, up to date and on a current month-to-month basis to be more transparent, and any errors are corrected on a timely manner.
Grant Overpayments - Criteria: Management was responsible for reviewing and reconciling monthly reimbursement requests from the contractor to the invoices submitted for reimbursement under the grant agreement in a timely manner. Condition: The State of New Hampshire Department of Health and Human...
Grant Overpayments - Criteria: Management was responsible for reviewing and reconciling monthly reimbursement requests from the contractor to the invoices submitted for reimbursement under the grant agreement in a timely manner. Condition: The State of New Hampshire Department of Health and Human Services appointed a contractor to administer, disburse and monitor Flexible Needs Funding (FNF) under this grant from December 20, 2023 through September 30, 2024, which changed how FNF reimbursement requests were processed. As part of this arrangement, the contractor compiled FNF information submitted via the System and submitted to the State for FNF reimbursement. It was determined that the System was reimbursed in error for duplicate invoices and formula errors within the reimbursement spreadsheets used by the contractor totaling $47,273. Of this overpayment, $45,925 was from a reimbursement received in December 2024 from the contractor’s final invoice covering July 2024 through September 2024 FNF reimbursements, which included duplicate invoices already reimbursed. Cause: With this change in process, the System did not implement appropriate procedures to review and reconcile reimbursements received from the State to the underlying FNF requests the contractor submitted via invoice for reimbursement under the grant agreement in a timely manner. This was primarily due to system reporting limitations of the new platform implemented by the contractor in July 2024, which limited the ability to effectively reconcile with FNF requests submitted. Effect: As a result, the System received overpayments from the grant totaling $47,273. Recommendation: Management should notify and refund the grantor for the funds received in duplication. Management should also implement controls to ensure this error does not reoccur. Responsible Party: Scott Sloane, Chief Financial Officer. Corrective Actions Taken or Planned: Management acknowledges the finding and has ensured controls are now implemented to prevent this error from recurring. The agreement with the contractor was not renewed. The System met with the State to review the new process for submission and reimbursement of FNF and reviewed with the State the controls that are now in place to prevent this error from recurring. The System refunded the overpayment to the State totaling $47,273 on March 27, 2025.
2024-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2025 Corrective Action: Management agrees with the finding and recommendation set forth within. Prior to fiscal year 2024, noncompetitive...
2024-001 Procurement, Suspension and Debarment Contact: Joseph Wilson Title: SVP, Procurement Phone Number: 202-760-4193 Estimated completion date: September 2025 Corrective Action: Management agrees with the finding and recommendation set forth within. Prior to fiscal year 2024, noncompetitive procurements completed followed the prior procurement policy that did not align with Uniform Guidance as relates to noncompetitive procurement justifications. The Corporation has since completed its revised procurement policies and procedures to conform with Uniform Guidance procurement requirements. Training on the Uniform Guidance procurement requirements is now ongoing and is required for all staff with procurement responsibilities to ensure (1) adherence to Uniform Guidance and (2) that appropriate justifications for noncompetitive contracts are used and properly documented. NeighborWorks has also implemented a new contracts management system to manage all aspects of vendor contracts from planning to closeout, including the contract expiration date. During fiscal year 2025, management will implement additional controls to ensure expenses charged to federal programs on contracts entered into prior to fiscal year 2024 are in compliance with the procurement requirements of the Uniform Guidance. This process will involve reviewing all existing contracts that previously lacked compliant noncompetitive procurement justifications and implementing corrective actions as needed.
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