Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significant consideration to what additional controls would be effective to ensure the proper amount of indirect costs are charged to all federal grants. To prevent another occurrence, the organization will: On the final report to HS, the agency refunded the indirect costs that were overbilled in error. Continue its current policy that no individual who prepares bill/draw should review their own calculation of the draw/billing. Another individual will review and approve costs allowable for the draw/billing and recalculate the indirect costs. Continue its current policy that the Director of Grants Management complete a detailed review of each grant reconciliation monthly, to ensure all costs charged to the grant are reasonable and necessary for the performance of the award. This review will include appropriate tests of indirect costs including ensuring the appropriate indirect cost base is used, all items required to be excluded from the indirect cost base are excluded, and the appropriate indirect cost rate is applied to the indirect cost base. Add additional step whereby the monthly grant reconciliations will be reviewed by the Controller or Chief Financial Officer.