Corrective Action Plans

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CONTACT PERSON: Travis Thomas, Director of Finance thomast@apps.anderson1.org CORRECTIVE ACTION: The School District is working and will continue to work to ensure that all purchases using federal funding over the School District’s small purchase threshold of $10,000 are procured in compliance with ...
CONTACT PERSON: Travis Thomas, Director of Finance thomast@apps.anderson1.org CORRECTIVE ACTION: The School District is working and will continue to work to ensure that all purchases using federal funding over the School District’s small purchase threshold of $10,000 are procured in compliance with the procurement code and federal procurement requirements. PROPOSED COMPLETION DATE: November 2024
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2024-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that al...
Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2024-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that all future deposits are made as required by the Regulatory Agreement. Action Taken: Management will fund delinquent deposit amount as soon as possible.
EAH will ensure that annual unit inspections are included in all tenant files going forward.
EAH will ensure that annual unit inspections are included in all tenant files going forward.
enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding. Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct coding is more appropriate. enCircle will also work to integrate payroll alloc...
enCircle believes the responses to findings 2024-001 and 2024-002 will remediate the concerns of this finding. Furthermore, enCircle will continue to work to decrease the number of allocations it actively uses when direct coding is more appropriate. enCircle will also work to integrate payroll allocations into its payroll provider directly, so that these allocations are updated automatically by HR when position roles change.
enCircle has communicated to grant management personnel the requirements regarding clothing allowances, especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely identified with a specific child and that also foster parents will submit receipts to...
enCircle has communicated to grant management personnel the requirements regarding clothing allowances, especially when using gift cards. Going forward enCircle will also require that all gift cards can be uniquely identified with a specific child and that also foster parents will submit receipts to enCircle regarding gift card purchases until the card is fully spent (if the card is not fully spent the foster parent will be liable to return it or the cash value remaining). enCircle will develop and implement an internal auditing procedure and cycle to regularly evaluate a sample of transactions throughout the year to ensure documentation and use is appropriate for all federal funds.
View Audit 328174 Questioned Costs: $1
During the monthly billing process, enCircle will now only bill up until the approved budget even if there are allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget amendment to allow for these costs and once approved include the previously unbilled ...
During the monthly billing process, enCircle will now only bill up until the approved budget even if there are allowed costs, irrespective of budget, in excess of budget amounts. enCircle will then request a budget amendment to allow for these costs and once approved include the previously unbilled costs in the next monthly billing. Furthermore, enCircle will work to preemptively request budget amendments by forecasting allowed expenditures. enCircle will evaluate if the monthly meeting between grant management personnel and financial personnel remains sufficient to ensure communication and grant compliance are adequate. If not, enCircle will change the meeting cycle to create sufficient communication including other means (Teams chats, etc…)
View Audit 328174 Questioned Costs: $1
2024-004 – Suspension and Debarment Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, and 10.582 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-0777-000 Award Peri...
2024-004 – Suspension and Debarment Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, and 10.582 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-0777-000 Award Period: July 1, 2023 - June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance CORRECTIVE ACTION PLAN (CAP): Recommendation: We recommend the District review suspension and debarment before entering into contracts with vendors. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will ensure that all vendors are not on the suspension and debarment listing. Official Responsible for Ensuring CAP: Mackenzie Dokkenbakken, Director of Finance Planned Completion Date for CAP: June 30, 2025
FINDING 2024-008 Corrective Action Plan The Organization’s senior leadership team has implemented procedures to track compliance deadlines and to monitor timely closing of financial periods. This monitoring will allow for the timely filing of the data collection form by the required deadline of the...
FINDING 2024-008 Corrective Action Plan The Organization’s senior leadership team has implemented procedures to track compliance deadlines and to monitor timely closing of financial periods. This monitoring will allow for the timely filing of the data collection form by the required deadline of the earlier of 30 days after the date of the independent auditor’s report or March 31, 2025. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: No later than March 31, 2025
FINDING 2024-007 Corrective Action Plan The Organization addressed the necessity of implementing a system of internal controls that would properly document the eligibility requirements set forth in the SSVF program during its most recent program audit (scope period January 1, 2022 – December 31, 20...
FINDING 2024-007 Corrective Action Plan The Organization addressed the necessity of implementing a system of internal controls that would properly document the eligibility requirements set forth in the SSVF program during its most recent program audit (scope period January 1, 2022 – December 31, 2023) with the U.S. Department of Veterans Affairs. Subsequent to the program audit, the Organization instituted a corrective action plan to follow that process. In a letter dated August 21, 2024, the U.S. Department of Veterans Affairs stated and confirmed that “corrective actions were taken in response to recommendations issued by the Office of Business Oversight (OBO) in its SSVF Grant Programmatic Review.” Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: August 21, 2024
FINDING 2024-006 Corrective Action Plan For fiscal year ending June 30, 2025, the Organization will implement a procedure to verify if any vendor or employee being paid over $25,000 will be checked against SAM to confirm whether or not the vendor or employee is included on the excluded parties list...
FINDING 2024-006 Corrective Action Plan For fiscal year ending June 30, 2025, the Organization will implement a procedure to verify if any vendor or employee being paid over $25,000 will be checked against SAM to confirm whether or not the vendor or employee is included on the excluded parties list. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025
FINDING 2024-005 Corrective Action Plan Refer to the corrective action plans for findings 2024-001, 2024-002 and 2024-003. Finding 2024-001 Corrective Action Plan Before the end of fiscal year June 30, 2024, Veterans Northeast Outreach Center, Inc. (the Organization) began implementing procedures...
FINDING 2024-005 Corrective Action Plan Refer to the corrective action plans for findings 2024-001, 2024-002 and 2024-003. Finding 2024-001 Corrective Action Plan Before the end of fiscal year June 30, 2024, Veterans Northeast Outreach Center, Inc. (the Organization) began implementing procedures to strengthen its system of internal controls. Included as part of this implementation the Organization will begin procedures where: • the Executive Director reviews and approves each weekly payroll by email. In addition, any changes to the payroll being approved that differs from the previous weekly payroll will be noted in the email and part of the approval process. This includes new hire compensation and any adjustments to current staff. • the COO notifies the Executive Director and Chief Financial Officer of any terminated employee that has been removed from applicable benefits, software applications, and physical access rights within the Organization. • all checks will be procured at the front desk by intake staff and logged into a check and wire log before being brought to the Finance Office where the checks are then copied, deposited, and filed. • rent rolls are regularly updated by housing staff and any updates are made to the Organization’s accounts receivable subledger. Additionally, the Organization will be reviewing outstanding tenant receivables on a monthly and quarterly basis to ensure timely collection of rent. • all payments, including reimbursement and credit card purchases, be reviewed for appropriate backup and approved by the applicable program manager and/or supervisor; and all invoices and backup will be filed in the appropriate accounts payable file. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025 FINDING 2024-002 Corrective Action Plan Management will work to identify a process of reviewing journal entries on a regular basis. The challenge with implementing a journal review process is the limited staff to facilitate a multi-level review of journal entries. The Organization will be discussing internally and with the Board of Directors a manner in which this can be accomplished. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025 FINDING 2024-003 Corrective Action Plan Beginning in December 2024, the Finance Department implemented procedures where all bank account reconciliations are performed in a timely fashion the month following the closing of the previous month. Additionally, beginning in June 2024, the Finance Department implemented policies and procedures to have monthly financial reports prepared and provided to the Organization’s Board of Directors by the fourth Wednesday of the subsequent month for review. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: July 1, 2024 FINDING 2024-004 Corrective Action Plan The Organization’s senior leadership team has implemented procedures to track compliance deadlines and to monitor timely closing of financial periods. This monitoring will allow for the timely filing of the Massachusetts UFR by the required deadline of November 15, 2024. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: November 15, 2024
Recommendation: We recommend the District implement procedures and controls to ensure correct procurement policy is being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Maintenance Service Supervis...
Recommendation: We recommend the District implement procedures and controls to ensure correct procurement policy is being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Maintenance Service Supervisor will ensure he is following the UGG procurement policy for entities being paid with federal dollars, instead of Minnesota Legal Compliance guidelines. Name(s) of the contact person(s) responsible for corrective action: Bob Hasz, Business Manager. Planned completion date for corrective action plan: June 30, 2025.
Recommendation: We recommend the District implement procedures and controls to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Food Service Director will search t...
Recommendation: We recommend the District implement procedures and controls to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Food Service Director will search the Sam.Gov website before contracting with vendors for $25,000 and over, in the future to verify the entity is not suspended or debarred. Name(s) of the contact person(s) responsible for corrective action: Bob Hasz, Business Manager. Planned completion date for corrective action plan: June 30, 2025.
The following is the Student Financial Aid Corrective Action Plan for the single Audit Finding for FY24. Criteria or Specific Requirement: – Special Tests and Provisions – Return of Title IV Funding (R2T4), 34 CFR Section 668.22 Finding Summary: The calculation and process for Return to Title IV (R2...
The following is the Student Financial Aid Corrective Action Plan for the single Audit Finding for FY24. Criteria or Specific Requirement: – Special Tests and Provisions – Return of Title IV Funding (R2T4), 34 CFR Section 668.22 Finding Summary: The calculation and process for Return to Title IV (R2T4) calculations were not processed correctly for a student with a Federal Pell Grant. Officials Responsible for Ensuring Corrective Action: Stacey Harris, Director, Student Financial Aid Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has implemented procedures to ensure Return to Title IV (R2T4) calculations are correct and the return of Title IV funds are accurate. To ensure precise Return to Title IV (R2T4) calculations for all students receiving Federal Pell Grant disbursements, each student's file will include an independent manual calculation which will be compared to the PeopleSoft system’s automated calculation. Written policies and procedures have been updated, with changes implemented as of August 31, 2024.
Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post ...
Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post Award Administrators to ensure timely submission of reports and strengthening of our internal monitoring procedures by tracking submission deadlines more closely. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024
Response: Management agrees with the finding and acknowledges UAS contract service agreements used when working with certain vendors did not contain the terms and conditions in regard to suspension and debarment. The contract service agreement will be enhanced to include the language similar to UAS ...
Response: Management agrees with the finding and acknowledges UAS contract service agreements used when working with certain vendors did not contain the terms and conditions in regard to suspension and debarment. The contract service agreement will be enhanced to include the language similar to UAS subrecipient contracts and purchase orders to meet compliance. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024
Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to unallowable payroll costs. This issue occurred due to a timing delay in processing an Employment Transaction Report (ETR). The payroll transfer, originally intended to be effective i...
Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to unallowable payroll costs. This issue occurred due to a timing delay in processing an Employment Transaction Report (ETR). The payroll transfer, originally intended to be effective in April 2024, was not processed until September 2024 of the following fiscal year. As a result, one grant was overcharged, while another grant was undercharged, leading to a misallocation of funds. To prevent similar issues, we will conduct monthly payroll reviews to ensure correct allocation of expenses and provide comprehensive staff training to reinforce the importance of timely and accurate payroll processing. Regular internal reviews and follow-ups will be conducted to monitor the effectiveness of these corrective actions, ensuring any further training or system improvements are implemented as needed. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024
Response: Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient ...
Response: Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient monitoring and communication between the subrecipient and our grants management team. To address this, we are implementing several corrective actions. These include establishing a stricter communication schedule with subrecipients to ensure timely submission of invoices and expense reports and strengthening our internal monitoring procedures by tracking submission deadlines more closely. Additionally, we will improve guidance and capacity-building efforts for subrecipients to ensure they understand reporting requirements, and we will conduct quarterly reviews of subrecipient expenses to proactively identify and mitigate reporting delays. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024
Finding: 2024-002: Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive gradua...
Finding: 2024-002: Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The College acknowledges the delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a retroactive graduation date change following a thesis review. We are revising our internal policy to ensure timely submission of enrollment status changes and will implement sample checks after each transmission date. Contact Person Responsible for Corrective Action: Deputy Director of Financial Aid, Eleanor Wu has implemented the corrective action plan. Anticipated Completion Date: Corrective action was completed by October 2024.
Finding: 2024-001: Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance Corrective Action Plan: The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure syst...
Finding: 2024-001: Special Tests and Provisions – Return of Title IV: Significant Deficiency in Internal Control over Compliance Corrective Action Plan: The College acknowledges the oversight in configuring the system for Spring 2024 enrollment breaks and has taken corrective measures to ensure system accuracy. At least two financial aid officers will now verify semester start/end dates and break periods, and the 60% mark will be calculated at the beginning of each semester. Additionally, the COD R2T4 calculator will be used for comparison with internal calculations. Withdrawal and R2T4 policies are also being updsated for the 2024-25 College catalog. Contact Person Responsible for Corrective Action: Deputy Director of Financial Aid, Eleanor Wu has implemented the corrective action plan. Anticipated Completion Date: Corrective action was completed by October 2024.
View Audit 328116 Questioned Costs: $1
Finding 505400 (2024-001)
Significant Deficiency 2024
Finding 2024-001: Gramm-Leach Bliley Act-Student Information Security Finding: The institution revised its information security policies in response to the revised requirements, however, these policies were not formally approved and adopted until January 2024. The policies implemented as of Januar...
Finding 2024-001: Gramm-Leach Bliley Act-Student Information Security Finding: The institution revised its information security policies in response to the revised requirements, however, these policies were not formally approved and adopted until January 2024. The policies implemented as of January 2024 contained all required elements, however, the College’s existing information security policies as of June 9, 2023 did not contain certain elements required by regulation as agreed to in the Program Participation Agreement. Cause: The institution was in the process of modifying existing policies to comply with federal requirements. These policies were not approved and adopted until January 2024. Corrective Actions Taken or Planned: 1. In July 2023, Lake Forest College established a dedicated “Information Security Manager” (ISM) position to oversee the implementation and compliance of GLBA requirements. This role includes the responsibilities of the GLBA-mandated “Qualified Individual,” ensuring clear oversight and accountability for maintaining the security of customer information. 2. In September 2023, the College’s CIO and the newly appointed ISM conducted a comprehensive review of all existing IT policies, procedures, and practices. This review identified gaps in compliance and resulted in the development of new policies and substantial revisions to existing ones, ensuring comprehensive alignment with GLBA requirements. 3. From October to December 2023, the newly drafted and revised policies underwent a detailed review and collaborative refinement process, incorporating feedback from the College’s IT Governance group. 4. In January 2024, the College’s Senior Leadership Team formally approved the new and revised policies, demonstrating the institution’s commitment to full GLBA compliance and establishing a robust information security management framework. 5. Moving forward, these policies will undergo annual reviews (per policy) and updates by the CIO, ISM, and the IT Governance committee to ensure ongoing compliance with evolving regulatory requirements and to proactively address any new risks or operational changes. Contact Person Responsible: Eric Wacker, Information Security Manager ewacker@lakeforest.edu Completion Date: January 2024
Condition: The Authority did not have controls in place to ensure Form 5100-127 and Form 5100-126 were filed within 120 days after the Authority's fiscal year-end. Planned Corrective Action: The Authority agrees with the finding. Due to turnover of staff formally responsible for filing the reports, ...
Condition: The Authority did not have controls in place to ensure Form 5100-127 and Form 5100-126 were filed within 120 days after the Authority's fiscal year-end. Planned Corrective Action: The Authority agrees with the finding. Due to turnover of staff formally responsible for filing the reports, the correct due date was not retained. Upon discovery of the missed due date, the Authority immediately filed the reports with the FAA. To ensure the reports are filed timely in the future, an online calendar has been established with reminders for important activities, such as filing due dates, renewals and debt service payments. All members of the Finance team have access to the online calendar to review, monitor and add important due dates. Contact person responsible for corrective action: Beverly Santamouris Anticipated Completion Date: June 30, 2024
Memo: Audit Findings 2023-2024 Submitted by: Karson Kent, University Registrar Date: 9/13/2024 Below is a description of and explanation for the 3 findings from the 23-24 audit pertaining to the Registrar’s office. Also included is an explanation of how the findings have been addressed, and the acti...
Memo: Audit Findings 2023-2024 Submitted by: Karson Kent, University Registrar Date: 9/13/2024 Below is a description of and explanation for the 3 findings from the 23-24 audit pertaining to the Registrar’s office. Also included is an explanation of how the findings have been addressed, and the action that has been taking to prevent them from happening in the future. ETBU uses the National Student Clearinghouse for enrollment reporting to the National Student Loan Data System. Case 1 – Student 1 withdrew from the spring term on 1/29/2024, but withdrawal was reported as end of fall 2023. Case 2 – Student 2 withdrew from the spring term on 1/31/2024, but withdrawal was reported as end of fall 2023. Error: The enrollment report was being pulled and sent to the National Student Clearinghouse (NSC) after the census date when roster certifications and withdrawal requests, up to that point, had been processed. Students 1 and 2 both withdrew during the roster certification period, which was before the census date, but after late registration had ended. Their withdrawals were processed in the Registrar’s office before the initial enrollment report was pulled, and since they received W’s for the term, they should have been reported for the term to the NSC. In researching the finding, it was discovered that the system is set up to only include students in the enrollment report who are enrolled as of the date that the first report is pulled. This means that students 1 and 2 were never included in the initial enrollment report for spring 2024, and therefore weren’t captured on any of the subsequent of term reports that notify the NSC of enrollment changes throughout the semester. This made it look like they never attended ETBU in the spring, which is why the NSC showed their withdrawal to be the end of the fall term. Action Taken: Students 1 and 2 enrollments for the spring 2024 term have since been corrected with the NSC. Additionally, since learning how the report is set up, the Registrar has been in discussion with the Director of Financial Aid and Institutional Research, to figure out the best timeline for processing the enrollment report moving forward. It has been determined that the initial enrollment report needs to be submitted as soon as late registration ends, so that everyone who is registered for the term is captured on the report. Once the roster certification period is over, students who have been reported as not attending will be dropped, and any University withdrawal request will be processed. Once those things have been done, the Registrar will submit the first subsequent of term enrollment report to the NSC. This will ensure that any enrollment changes that have happened after registration ended up to census date get reported within the time frame needed by Financial Aid. Case 3 – Student 3 was reported as withdrawn after the fall 2023 term, but actually graduated. Error: Student 3 should have been reported to the NSC as a fall 2023 graduate, but was not included on the graduation report. In investigating it appears student 3’s degree was conferred after the fall graduation report had already been submitted, and the Registrar was not made aware of the discrepancy. Since student 3 was not reported as graduated for fall 2023, and was not enrolled in the spring 2024 term, they were considered withdrawn through the the NSC. Action Taken: Student 3’s status has been changed from withdrawn for the fall 2023 term to graduated, with the NSC. To prevent this from happening in the future, the Graduation Certification Officer has been made aware to notify the Registrar anytime a degree is conferred outside of the normal time frame, so that it can promptly be reported to the NSC. As an added measure moving forward, after degrees have been conferred for a standard term, the Records Assistant will double check all the degrees conferred to help ensure that nobody was missed.
Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originat...
Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.
The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehe...
The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.
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