CUAHSI has resolved this issue by halting all draws against NSF awards in late March 2023 (when this non-compliance became known to the current Executive Director) until June 15th, 2023, when CUAHSI completed a draw from an NSF award after supporting documents for expenses were submitted with a certified SF-270 to be reviewed and approved by NSF. The SF-270 and backup documents were saved in a single secure document location and filed accordingly. This procedure has been followed since the June 2023 draw; related drawdown procedures in our Federal Grant Management Policies and Procedures Manual have been adhered to as well. Each draws follow segregation of duties and an internal approval process. In once-yearly financial reviews (off-season with required single audits), process documentation will be reviewed by Management and relevant CUAHSI Officers (e.g., Treasurer) to ensure policy adherence.