EIN: 112077903
UEI: NLJJZLAXN863
Audited by: GIAMPAOLO & ASSOCIATES
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 13, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 13, 2027 (164 days from today).
What is a management decision? →FAC accepted this audit on September 26, 2025 — management decision was due March 26, 2026.
FAC accepted this audit on September 28, 2024 — management decision was due March 28, 2025.
FAC accepted this audit on October 11, 2023 — management decision was due April 11, 2024.
The Authority continues to run a deficit in the Central Office Cost Center (COCC) primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended Low Income Public Housing (LIPH) funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31, 2022, the Authority has accumulated in excess of $5,487,478, in COCC administrative operating costs above those normally covered by management fees, capital asset fees ad bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD s commitment in accordance with the Annual Contributions Contract (ACC) with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. It was noted that the amount owed to the LIPH program decreased in the current year. This is a repeat of finding 2021-001. Criteria: OMB-87 regarding eligible and ineligible costs. Cause: The Authority has not established controls to ensure proper accounting for cash balances pertaining to Asset Management Projects and continues to use a central checking system to disburse funds. There is also a lack of oversight and long-range planning in accordance with HUD s requirements. Effect: The Authority was not in compliance with the allowable costs criteria for the federal program. Questioned Costs: $0 Recommendation: We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan: See corrective action plan.
Show full finding ▾Hide full finding ▴2022-001 COCC U.S Department of Housing and Urban Development 14.850 Public and Indian Housing Condition: The Authority continues to run a deficit in the Central Office Cost Center (COCC) primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended Low Income Public Housing (LIPH) funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31, 2022, the Authority has accumulated in excess of $5,487,478, in COCC administrative operating costs above those normally covered by management fees, capital asset fees ad bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD s commitment in accordance with the Annual Contributions Contract (ACC) with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. It was noted that the amount owed to the LIPH program decreased in the current year. This is a repeat of finding 2021-001. Criteria: OMB-87 regarding eligible and ineligible costs. Cause: The Authority has not established controls to ensure proper accounting for cash balances pertaining to Asset Management Projects and continues to use a central checking system to disburse funds. There is also a lack of oversight and long-range planning in accordance with HUD s requirements. Effect: The Authority was not in compliance with the allowable costs criteria for the federal program. Questioned Costs: $0 Recommendation: We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan: See corrective action plan.
Finding 2022-00 I - COCC deficit and the use of LIPH funds in violation of HUD Rule Auditee's Response and Planned Corrective Action The Authority is working to gather the information necessary to complete an analysis of the benefits charged to each AMP and COCC for the above referenced finding. There is a meeting scheduled for October 16, 2023. HUD has been informed regarding the status of the finding. Planned Implementation Date of Corrective Action: December 2023 Person Responsible for Corrective Action: Ed Cumming, Executive Director
2021-001
During review of the Authority s budgeting process, it was noted that the Board did not approve the 2022 fiscal year budget until March 2022. The Authority is required to complete and approve the budget before the start of the fiscal year. Criteria: PHAs implementing asset management shall develop and maintain a system of budgeting and accounting for each project in a manner that allows for analysis of actual revenues and expenses. Prior to the beginning of the fiscal year, a PHA is required to prepare an operating budget and the PHA s Board of Commissioners is required to review and approve the budget by resolution. Cause: The Authority was transitioning between accountant s during the budgetary process. Effect: The Authority was not in compliance with the project-based budgeting and accounting requirement. Questioned Costs: $0 Recommendation: We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that the budget is prepared and approved timely. PHA Response and Corrective Action Plan: See corrective action plan.
Show full finding ▾Hide full finding ▴2022-002 Project-Based Budgeting and Accounting U.S Department of Housing and Urban Development 14.850 Public and Indian Housing Condition: During review of the Authority s budgeting process, it was noted that the Board did not approve the 2022 fiscal year budget until March 2022. The Authority is required to complete and approve the budget before the start of the fiscal year. Criteria: PHAs implementing asset management shall develop and maintain a system of budgeting and accounting for each project in a manner that allows for analysis of actual revenues and expenses. Prior to the beginning of the fiscal year, a PHA is required to prepare an operating budget and the PHA s Board of Commissioners is required to review and approve the budget by resolution. Cause: The Authority was transitioning between accountant s during the budgetary process. Effect: The Authority was not in compliance with the project-based budgeting and accounting requirement. Questioned Costs: $0 Recommendation: We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that the budget is prepared and approved timely. PHA Response and Corrective Action Plan: See corrective action plan.
Finding 2022-002 Project-Based Budgeting and Accounting Auditee's Response and Planned Corrective Action The Authority will implement policies and procedures to ensure that the operating budget is on the January Board Agenda going forward. The budget will be presented to the board for review an adoption and documented in the minutes. Planned Implementation Date of Corrective Action: December 2023 Person Responsible for Corrective Action: Ed Cumming, Executive Director
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
2021-001 Finding ? (Public and Indian Housing ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31, 2021, the Authority has accumulated in excess of $6,264,308, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, December 31, 2022
Show full finding ▾Hide full finding ▴2021-001 Finding ? (Public and Indian Housing ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31, 2021, the Authority has accumulated in excess of $6,264,308, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, December 31, 2022
2021-001 Finding ? (Public and Indian Housing ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31, 2021, the Authority has accumulated in excess of $6,264,308, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, December 31, 2022
2020-001
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2020, the Authority has accumulated in excess of $5,637,791, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2022
Show full finding ▾Hide full finding ▴Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2020, the Authority has accumulated in excess of $5,637,791, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2022
Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2020, the Authority has accumulated in excess of $5,637,791, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2022
2019-002
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2019, the Authority has accumulated in excess of $4,506,730, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2021
Show full finding ▾Hide full finding ▴Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2019, the Authority has accumulated in excess of $4,506,730, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2021
Finding ? (Low Rent ? (14.850a)) The Authority continues to run a deficit in the COCC primarily because of legacy costs (Health Insurance and Pension costs) associated with former employees, as required by long term state contracts. COCC has expended LIPH funds to support the COCC operations in violation of Federal Rules and Regulations. Through the year ended December 31,2019, the Authority has accumulated in excess of $4,506,730, in COCC administrative operating costs above those normally covered by management fees, capital asset fees and bookkeeping fees. Though it appears that overall the Authority does not have a Going Concern issue as a result of HUD's commitment in accordance with the ACC with housing authorities for the subsequent twelve (12) months, by continuing to operate the COCC with a negative cash flow over an extended period of time, the COCC will continue to use LIPH funds in violation of HUD rules. Questioned Costs ? $0 Criteria ? OMB-87 regarding eligible and ineligible costs. Effect of Condition ? Lack of oversight and long-range planning in accordance with HUD?s requirements. Cause of Condition ? The Authority has not properly accounted for cash balance pertaining to project AMPs and continues to use a central checking system to disburse funds. Recommendation ? We recommend that the Authority establish internal control procedures over the budgeting process sufficient to ensure that each program operates both in accordance with its budget and within its means, and for the Authority to provide a work-out plan for the COCC to substantially reduce its costs or to generate additional revenue. PHA Response and Corrective Action Plan ? The Authority believes it has implemented a management strategy to not only respond to the above finding but to eliminate it with both short- and long-term strategies. As of January 1, 2019, management and the board decided to regroup the public housing AMPs in hope the effect will allow for more self-sustaining AMPS. By doing this it will improve the central office cost center by allocating the costs to the appropriate AMP, and not be absorbed by the COCC. In addition to the reorganization, the Authority is in the process of converting public housing units to project-based voucher units under the RAD program. As all units are converted this will alleviate the Authority of maintenance costs and other administrative costs that are currently absorbed by the COCC. PHA Contact and Resolution Date William Scheibeler, Interim Executive Director, June 30, 2021
2018-001
FAC accepted this audit on September 29, 2019 — management decision was due March 29, 2020.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
FAC accepted this audit on September 28, 2018 — management decision was due March 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
FAC accepted this audit on October 31, 2017 — management decision was due May 1, 2018.
GSA_MIGRATION
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