Responsible contacts: Laura, CFO; Agnes, Controller; Steve, Staff Accountant - AR; the Program Director responsible; Staff Accountant - AP (vacant). Interim AP: Trina performs the coding check under Agnes' review until AP is filled and trained. Program staff supply expense support; Trina supports historical review. AEA will evaluate each expenditure based on its documented business purpose, the nature of the activity supported, and the benefit received by the Federal award. The approved budget will guide classification but will not, by itself, establish that a cost is allowable or allocable. Expenses supporting administrative activities will be classified under the applicable award’s administrative-cost requirements, with consistent direct or indirect treatment and no duplicate recovery. Classification decisions and supporting documentation will be retained. 1. Budgeted Expenses visibility. The Program Director will provide the current approved detailed budget, category definitions, and coding instructions to staff who request, incur, or approve expenses, and to AP, Steve, and Agnes. Approved amendments will be shared promptly. Program staff will document each expense's purpose, benefiting activity, fund/award, and proposed category. Evidence of budget distribution and staff instruction will be retained. 2. Expenses coding. AP should also review the invoice, business purpose, benefiting activity, and allocation support. A cost should not pass review merely because it fits an available budget line. Costs must satisfy award restrictions, budget category, receive consistent treatment, and be adequately documented. AP will compare each expense and its support with the approved budget categories and coding instructions before accepting grant coding. Incorrect, unclear, or unsupported submissions will be rejected as coded and returned to Program staff. AP will work with the Program to document corrections and escalate unresolved disagreements to Agnes, then Laura as needed. Disputed coding will not support an award charge or claim until resolved. 3. Budget – Actual expense review. Monthly and before each financial report, Steve will prepare an expense report with the approved budget, current-period and cumulative actual expenses, remaining budget, and variance by category. Actuals will reconcile to the general ledger. Program will review the transaction-level coding. AP and Program staff will investigate variances and classification errors, including administrative costs in program categories. Agnes will review the analysis and proposed corrections; Steve will update reports after approved entries are posted. Program retains financial-review responsibility. Steve or the designated submitter will release only the approved version; later coding changes require renewed review. Oversight and historical correction. Agnes, the Program Director, and Trina will review the expenditures and similar 2026 charges through implementation, document conclusions, and process supported corrections through the journal-entry approval workflow. Laura will oversee implementation and address significant classification judgments, required funder resolution, and report revisions. Anticipated completion For awards ending, Sept 30, 2026, historical review will be completed by October 15, 2026. Interim controls begin October 1, 2026; procedures and training by October 30, 2026; historical review by November 30, 2026. Anticipated completion: January 15, 2027. Monthly monitoring and pre-submission approvals continue thereafter.