Corrective Action Plans

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Finding 538769 (2024-002)
Significant Deficiency 2024
Official withdrawals will be calculated for potential R2T4 upon receipt of notification from the records department. Unofficial withdrawals will be completed within 45 days of receipt of notification from the records department. Financial Aid will keep a record of when a withdrawal is received and w...
Official withdrawals will be calculated for potential R2T4 upon receipt of notification from the records department. Unofficial withdrawals will be completed within 45 days of receipt of notification from the records department. Financial Aid will keep a record of when a withdrawal is received and when R2T4s are processed. This spreadsheet will be checked on a regular basis. R2T4 calculations will be checked for accuracy in Banner by the director or another staff member before submission.
View Audit 349478 Questioned Costs: $1
Finding 538768 (2024-001)
Significant Deficiency 2024
Annually update the college website with contract and/or cost information regarding the third-party provider. Provide contract information URL to ED for publication in the Cash Management Contracts Database.
Annually update the college website with contract and/or cost information regarding the third-party provider. Provide contract information URL to ED for publication in the Cash Management Contracts Database.
Management deposited the underfunded amount in to the replacement reserve account prior to issuance of the audit.
Management deposited the underfunded amount in to the replacement reserve account prior to issuance of the audit.
View Audit 349462 Questioned Costs: $1
Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awarene...
Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awareness: OBT has provided training to all relevant personnel, especially those involved in procurement, expenditure documentation collection, and allocation designation to ensure they understand the requirements of federal awards and the importance of proper documentation. 3. New Technology: OBT Has purchased new technology to better support documentation collection and allocations for all orders made. 4. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement all four steps within this plan by March 31, 2025, with ongoing monitoring and improvement.
View Audit 349461 Questioned Costs: $1
Plan: 1. Mandatory Time and Program Effort Records: OBT will continue to allocate as many staff as possible to a single contract that reflects where they spend 100% of their time. Further, as of July 2025, OBT will only have one such federal contract and this contract has a required staffing patte...
Plan: 1. Mandatory Time and Program Effort Records: OBT will continue to allocate as many staff as possible to a single contract that reflects where they spend 100% of their time. Further, as of July 2025, OBT will only have one such federal contract and this contract has a required staffing pattern of six full-time staff who must spend 100% of their time on this program. 2. Internal Controls: Payroll reports are reviewed every payroll for accuracy. OBT has implemented internal controls to review and verify the accuracy of time and effort records, ensuring that charges to federal awards comply with regulations. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement this plan by March 31, 2025, with ongoing monitoring and improvement.
View Audit 349461 Questioned Costs: $1
Finding 2024-005 – Special Tests and Provisions – Public Housing Waiting List ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA review its policies and procedures surrounding the selections of applicants to ensure compliance with federal, state and loca...
Finding 2024-005 – Special Tests and Provisions – Public Housing Waiting List ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA review its policies and procedures surrounding the selections of applicants to ensure compliance with federal, state and local regulations. The PHA should then develop a documentation system that ensures a clear trail can be provided on the movement of applicants while on the waiting list. Finally, they should ensure that documentation is available for review when requested. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will review our policies and procedures over waitlist management and updated as necessary. We will work with our software provided to obtain the current listing and best practices for maintaining data in the system. Finally, we will conduct an outreach to all applicants on the current list to obtain updated applications and determine eligibility status. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-004 – Special Tests and Provisions – Public Housing Inspections ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA schedule annual inspections to occur in conjunction with the annual recertifications. Alternatively, the PHA could schedule al...
Finding 2024-004 – Special Tests and Provisions – Public Housing Inspections ALN 14.850 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA schedule annual inspections to occur in conjunction with the annual recertifications. Alternatively, the PHA could schedule all annual inspections to occur at one time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct a review of our existing inspection procedures and update the timing of inspections to align with the annual recertification dates. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-003 – Special Tests and Provisions – SEMAP reporting ALN 14.871 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA personnel obtain the appropriate training for SEMAP documentation and certification and appropriately document the SEMAP reports in futur...
Finding 2024-003 – Special Tests and Provisions – SEMAP reporting ALN 14.871 – Noncompliance & Significant Deficiency Recommendation: We recommend that the PHA personnel obtain the appropriate training for SEMAP documentation and certification and appropriately document the SEMAP reports in future years. We also recommend that the PHA utilize the existing computer system to adequately document SEMAP on a regular basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct regular training sessions for staff involved in SEMAP submission process to reinforce proper procedures and documentation management. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear ...
Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear audit trail should be maintained to ensure proper approval, as well as documentation to support the allowability and eligibility of costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will enhance our internal controls over purchasing and Develop detailed procedures for creating, approving, and managing purchase orders. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
Finding 2024-001 – Capital Fund Program Accounting– Cash Management & Program Compliance ALN 14.872 – Grant years 2018, 2019, 2021, 2022 – Noncompliance & Material Weakness Recommendation: We recommend that the PHA establish an appropriate cash management procedure that facilitates timely requests ...
Finding 2024-001 – Capital Fund Program Accounting– Cash Management & Program Compliance ALN 14.872 – Grant years 2018, 2019, 2021, 2022 – Noncompliance & Material Weakness Recommendation: We recommend that the PHA establish an appropriate cash management procedure that facilitates timely requests and reimbursements of grant costs as incurred. We also recommend that the applicable PHA staff undergo Capital Fund training to ensure grant requirements are met prior to their deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will conduct a comprehensive review of existing cash management policies and procedures and update policies to align with current best practices and regulatory requirements for the Capital Fund Program. We will ensure that all staff members are informed of the updated policies and receive appropriate training. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.
FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The district did not have proper internal controls in place and documentation to track property or capital assets that were purchased with federal grant funds. Conta...
FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund - Equipment and Real Property Management Summary of Finding: The district did not have proper internal controls in place and documentation to track property or capital assets that were purchased with federal grant funds. Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As federal funds are used and expended, property and capital assets that meet or exceed the threshold will be entered on a spreadsheet by the Business Manager or Grant Administrator which will contain a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number (FAIN)), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and use and condition of the property Anticipated Completion Date: All expenditures initiated after March 12, 2025
FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants Assistance Listings...
FINDING 2024-001 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: Federal Agency: Department of Education Federal Programs: COVID-19 - Special Education Grants to States; COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027; 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-042-ARP; 22619-042-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement(s): Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Dawn Mason, Business Manager, DeKalb Co. Eastern CSD Contact Phone Number and Email Address: 260-868-2125; dmason@dkeschools.com Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The expenditures referenced in the finding were expended from the American Rescue Plan Special Education grant funds which were fully expended during the audit period. All future expenditures triggering procurement and suspension and debarment requirements will include implementing the following procurement policies. Reference Procurement Standards 2 CFR 200.318 Districts may not enter into contracts with entities that have been suspended or debarred from participating in contracts with federal funds. For contracts over $25,000, districts must verify a contractor is not excluded or disqualified. Contractors must be verified in one of three ways: 1. Checking the System for Award Management (SAM) (www.SAM.gov) 2. Collecting a certificate from that contractor. 3. Adding a clause or condition to the covered transaction with that contractor. (Recommended) **Proper verification and documentation must be sent to the LEA for audit purposes. Methods of Procurement Where specific EDGAR/UG thresholds apply, Districts must meet baseline requirements for procurement. If State or local rules have more restrictive thresholds, the most restrictive rule must be followed. E INDIANA STATE BOARD OF ACCOUNTS 25 Informal Procurement Procedures 1. Micro-purchase (0-$50,000) Dekalb County Eastern CSD has self-certified micro-purchases for up to $50,000 Micro-purchases may be awarded without soliciting competitive quotes if the district considers the price to be reasonable. Quotes must be attached to the invoice/checks for proper documentation and retained by the LEA. 2. Small Purchase ($50,000 – $150,000) Three quotes are required prior to purchase unless the purchase comes from a “Sole Source” vendor. Small purchases are required to be ordered under a purchase order unless in an emergency. Additional quotes must be presented along with the purchase order prior to being approved by the LEA. Formal Procurement Procedures 1. Sealed Bids (above $150,000) Bids must be solicited from an adequate number of suppliers, providing them with sufficient response time prior to the opening of the bids. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. 2. Competitive Proposals (above $150,000) The Request for Proposal method is used for procurements in which factors other than cost play a significant role. Per IC 5-22-9, when a purchasing agent makes a written determination that the use of competitive sealed bidding is either not practicable or not advantageous to the governmental body, the purchasing agent may award a contract using this procedure instead of competitive sealed bidding. This provides a formal process for the procurement of goods and/or services for which price is not the sole factor in the selection of a vendor or vendors. Proper advertisement and procedures must be followed per IC 5-22 and corresponding documentation must be presented to the LEA prior to any final approval or purchases being made. Noncompetitive (Sole Source) All sole source procurements require adequate written justification and must be attached to the corresponding purchase order or payment. Anticipated Completion Date: All expenditures initiated after March 12, 2025
FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the findin...
FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to procurements thresholds, ACS will prepare a policy to follow the necessary federal guidelines. For small purchases, three quotes or bids will be obtained to ensure compliance with the procurement guidelines. For all vendors expected to exceed over $25,000 in expenditures will be kept in a binder by the Special Ed Director to ensure that they are not suspended or debarred from federal awards. The CFO will then review and approve the documentation supporting this via signature. Anticipated Completion Date: June 30, 2025
FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective A...
FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Bethany Cmar Contact Phone Number and Email Address: 765-641-2126 (Bcmar@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When it comes to expenditures for non-public schools, ACS will assign a unique tracking number to each school, allowing expenditures to be easily traced for this requirement. The overall earmarking requirements will be compiled annually by the Special Education Director and sent to the CFO for review and approval, ensuring compliance with the requirements. Anticipated Completion Date: March 31, 2025
FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of C...
FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For eligibility, the federal grants director will prepare the PE report and enrollment and poverty data, and will give to the Assistant Superintendent for review and approval via signature. Anticipated Completion Date: December 31, 2025
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our Information Technology department to ensure the criteria used for triggering the notification emails is correct a...
Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our Information Technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the Financial Aid department to review to then send the appropriate notification. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: May 31, 2025
Condition: The College did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The College has begun training additional individuals on the reconciliation process and has updated its procedures to include what documentation needs to be retained on a monthly ...
Condition: The College did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The College has begun training additional individuals on the reconciliation process and has updated its procedures to include what documentation needs to be retained on a monthly basis to ensure accuracy between the amount the College shows as disbursed and the amount the Department of Education shows has been disbursed. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025
Condition: Out of 60 students tested for return to Title IV, we identified 24 students whose calculations were performed incorrectly. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identifying those students ...
Condition: Out of 60 students tested for return to Title IV, we identified 24 students whose calculations were performed incorrectly. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identifying those students who unofficially withdrew. Once the students are identified, individuals with the appropriate skills and knowledge would be able to determine if a Return of Title IV calculation is necessary, and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2025
View Audit 349445 Questioned Costs: $1
Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2...
Auditee Response: Management concurs with the finding. A new financial reporting calendar has been implemented and distributed to all staff. A formal review and approval process for financial reports has been implemented. The report for the quarter ended June 2024 will be submitted by end of March 2025.
Auditee Response: Management concurs with the finding. We have passed the relevant adjustments to correct the misclassification in our FY24 financial statements. We will also update our accounting policies and procedures Per the Audit recommendation. The adjusted financial statements will be submitt...
Auditee Response: Management concurs with the finding. We have passed the relevant adjustments to correct the misclassification in our FY24 financial statements. We will also update our accounting policies and procedures Per the Audit recommendation. The adjusted financial statements will be submitted to the federal awarding agency by the end of March 2025.
View Audit 349443 Questioned Costs: $1
Corrective Action Plan HCAP’s current procedures require the selection of auditors at least every five years. The request for proposal and selection of auditors for the fiscal year ended March 31, 2024 audit caused unexpected complications and delays in completing the audit and ultimately the filing...
Corrective Action Plan HCAP’s current procedures require the selection of auditors at least every five years. The request for proposal and selection of auditors for the fiscal year ended March 31, 2024 audit caused unexpected complications and delays in completing the audit and ultimately the filing of the single audit report to the Federal Audit Clearinghouse. The single audit for the fiscal year ended March 31, 2024 is expected to be submitted prior to March 28, 2025. The lessons learned during the 2024 audit will contribute to an expeditious and timely 2025 audit. HCAP will work diligently with its audit firm to ensure that future single audit reports are filed timely with the Federal Audit Clearinghouse. Completion Date: Completion date of the CAP is expected to be prior to March 28, 2025. Contact Person Responsible: Lynnelle Hasegawa, Director of Finance.
Finding 2024-003, Unallowable Expense (Assistance Listing 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the program. Assistance Listing...
Finding 2024-003, Unallowable Expense (Assistance Listing 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the program. Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic, requires that costs allocated to the program meet these criteria to ensure compliance with federal regulations. Response: WJCS acknowledges the audit finding related to an unallowable expense charged to the Certified Community Behavioral Health Clinic program. We agree with the recommendation to strengthen internal controls and have identified the cause as an isolated error due to invoices posting in the ledger prior to approval. To address this, we updated the accounts payable system so invoices will not post to the general ledger until approved. Estimated Completion Date: These corrective actions were implemented in February 2025.
Finding 2024-004, Documentation of Case Note Review (Assistance Listing 16.575) Persons Responsible Katrina Schermerhorn, Assistant Executive Director, Children, Youth & Family Services Comment: Per 2 CFR § 200.303(a) (Internal Controls). All recipient and subrecipient must establish, document, an...
Finding 2024-004, Documentation of Case Note Review (Assistance Listing 16.575) Persons Responsible Katrina Schermerhorn, Assistant Executive Director, Children, Youth & Family Services Comment: Per 2 CFR § 200.303(a) (Internal Controls). All recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. Response: Intake forms and Case numbers- In accordance with the requirements outlined by OVS, client names must be excluded from all documentation. Instead, client identification will be represented solely by client numbers. To maintain the integrity and accuracy of client information, an internal CVASSP tracking log designated for internal use only will be maintained, containing both client names and their corresponding numbers. The program coordinator will conduct monthly reviews of this log to ensure the information remains accurate and up-to-date. Audit Forms- Client folders undergo rigorous monitoring to maintain high standards of documentation. Each week, the program supervisor conducts a thorough review of all new cases to ensure that all required documentation is accurately completed. Additionally, the program coordinator performs quarterly audits of a random selection of files to assess compliance with the standards set forth by OVS and WJCS. Following established recommendations, a review form will be added to each case record upon completion of the review process. This form will include the date of the review and the signature of the reviewer, providing clear and transparent documentation of compliance efforts. This systematic approach not only enhances accountability but also fosters continuous improvement in case management practices. Estimated Completion Date: 4/1/2025
Finding 2024-002, Timesheet – Timekeeping (Assistance Listing 16.575 and 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk Controller Comment: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual em...
Finding 2024-002, Timesheet – Timekeeping (Assistance Listing 16.575 and 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk Controller Comment: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Response: In January 2025, WJCS implemented an automated time and attendance system for staff to track time which integrates with the payroll and financial systems to ensure appropriate allocations to Federal awards. Prior to implementation of the new system weekly manual timesheets were used to track staff time and attendance on Federal contracts. However, these manual timesheets were not integrated into a standard agency-wide payroll processing system. The new system enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations. Estimated Completion Date: The agency-wide time and attendance system was implemented in January 2025.
Finding 2024-001, Expense Allocations - Financial Management (Assistance Listing 16.575) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.302(a) (Financial Management), all recipient and subrecipient financial management systems mus...
Finding 2024-001, Expense Allocations - Financial Management (Assistance Listing 16.575) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk, Controller Comment: Per 2 CFR § 200.302(a) (Financial Management), all recipient and subrecipient financial management systems must be sufficient to track expenditures and establish that funds have been used in accordance with federal statutes, regulations, and the terms and conditions of the federal award. Response: WJCS acknowledges the audit finding regarding the misallocation of occupancy expense. We are committed to strengthening our internal controls by implementing a more structured review process for expense allocations and will provide staff training on accurate cost classification. In addition, we will formalize documentation procedures to support updated automated expense allocations. Estimated Completion Date: The additional review procedures will be implemented by March 31, 2025, and will work to update financial system expense allocations by June 1, 2025
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