EIN: 362581098
UEI: DGN3FFPKQW15
Audited by: CHERRY BEKAERT LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 September 30, 2026 (26 days from today).
What is a management decision? →The College did not maintain documentation of its performance of internal controls, and therefore, could not show documentation of reviews and approvals. Cause: The College did not implement a formal review and approval process over student financial aid until the Spring 2025 term and there is no formal review over return of Title IV calculations. Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure documentation of reviews and approvals. Context: For a sample of 23 students tested, during the summer and fall 2024 terms the College did not maintain documentation supporting the review and approval process for all of the students tested. The process was subsequently corrected, enabling the College to provide appropriate documentation of review for the spring 2025 term for the sample of 17 students tested. For a sample of 2 withdrawal students, the College did not perform a formal review over return of Title IV calculations for neither student tested. Repeat Finding: This is a repeat finding of 2024-001. Effect: We were unable to verify whether controls were properly designed or operating effectively. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Show full finding ▾Hide full finding ▴Material Weakness Finding 2025-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements. Condition: The College did not maintain documentation of its performance of internal controls, and therefore, could not show documentation of reviews and approvals. Cause: The College did not implement a formal review and approval process over student financial aid until the Spring 2025 term and there is no formal review over return of Title IV calculations. Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure documentation of reviews and approvals. Context: For a sample of 23 students tested, during the summer and fall 2024 terms the College did not maintain documentation supporting the review and approval process for all of the students tested. The process was subsequently corrected, enabling the College to provide appropriate documentation of review for the spring 2025 term for the sample of 17 students tested. For a sample of 2 withdrawal students, the College did not perform a formal review over return of Title IV calculations for neither student tested. Repeat Finding: This is a repeat finding of 2024-001. Effect: We were unable to verify whether controls were properly designed or operating effectively. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Finding 2025-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely retrieval of all student records and the proper documentation of reviews and approvals to meet regulatory requirements and to improve accountability in the Student Financial Aid Cluster. Corrective Actions: Management agrees with this finding. The College admits that before Spring 2025, formal documentation for review and approval of financial aid processes, including Return of Title IV (R2T4) calculations, was not consistently kept. Although controls were performed in most cases, the lack of documented evidence for students selected prior to the internal processing improvements prevented demonstrating control effectiveness, which is required under the Uniform Grant Guidance. Corrective actions implemented as follows: 1. Formal SOP Implementation Developed and implemented standardized SOPs for: 1. Financial Aid packaging and disbursement 2. Return of Title IV (R2T4) calculations 3. Review and approval workflows 2. Documentation & Audit Trail Controls 1. Introduced mandatory review/approval checklists for all financial aid transactions 2. Implemented centralized digital storage of supporting documentation 3. Segregation of Duties & Oversight 1. Established defined roles for: Preparer, Reviewer, Final approver. 4. Ongoing Monitoring 1. Monthly internal compliance reviews 2. Quarterly audit-readiness assessments led by senior leadership Timeline: Process corrections implemented in Spring 2025; Full compliance expected by June 30, 2026 Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884
2024-001
The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2025. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions. Context: Of our 7 students selected for testing, all of the students tested had status changes reported to the NSLDS after 60 days. Repeat Finding: This is a repeat finding of 2024-002. Effect: The College did not report status changes to the NSLDS timely. Recommendation: The College should put in place an internal control to timely capture student changes so they can be reported to the NSLDS in a timely manner. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Show full finding ▾Hide full finding ▴Nonmaterial Noncompliance Findings Finding 2025-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Compliance Requirement: Special Test and Provisions – NSLDS Reporting Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change. Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2025. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions. Context: Of our 7 students selected for testing, all of the students tested had status changes reported to the NSLDS after 60 days. Repeat Finding: This is a repeat finding of 2024-002. Effect: The College did not report status changes to the NSLDS timely. Recommendation: The College should put in place an internal control to timely capture student changes so they can be reported to the NSLDS in a timely manner. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Finding 2025-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: Management concurs with this finding. The College did not consistently report student status changes to NSLDS within the required 60-day timeframe due to inefficient tracking processes and system misalignment between internal records and reporting systems. Corrective actions implemented as follows: 1. Automated Tracking & Reporting Calendar 1. Established a compliance calendar with hard deadlines (<30 days internal target) 2. System Integration Improvements 1. Enhanced data alignment between: Ellucian Colleague, National Student Clearinghouse, and NSLDS 3. Accountability Structure 1. Assigned a designated compliance owner for NSLDS reporting 2. Introduced escalation protocols for missed deadlines 4. Monitoring & Reporting 1. Monthly compliance certification to senior leadership Timeline: Process corrections implemented in Summer 2025; Full compliance expected in Fall 2025 onward Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884
2024-002
The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system. Cause: The College uses the date they reported the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system. Context: Of the population of 40 tested, 24 of the disbursement dates in the COD system did not match student records. Repeat Finding: This is a repeat finding of 2024-004. Recommendation: The College should put in place an internal control to ensure student disbursement dates are accurately reported to the COD system. Management Response: The College concurs with this finding.
Show full finding ▾Hide full finding ▴Nonmaterial Noncompliance Findings Finding 2025-003 - Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Reporting Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement received by the student. Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system. Cause: The College uses the date they reported the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system. Context: Of the population of 40 tested, 24 of the disbursement dates in the COD system did not match student records. Repeat Finding: This is a repeat finding of 2024-004. Recommendation: The College should put in place an internal control to ensure student disbursement dates are accurately reported to the COD system. Management Response: The College concurs with this finding.
Finding 2025-003 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system Corrective Action Plan: Objective: To ensure the Financial Aid office reports the actual disbursement date the student receives the Direct Loan and/or Pell funds to the COD system. Corrective Actions: Management concurs with this finding. The College acknowledges that disbursement dates reported to COD reflected submission dates rather than actual student disbursement dates, resulting in inconsistencies. Corrective actions implemented as follows: 1. Definition Standardization 2. System Configuration & Process Update 1. Actual disbursement dates are captured at the transaction level 2. Data feeds into COD accurately once Financial Aid is converted to Ellucian 3. Reconciliation Controls 1. Monthly reconciliation between: 1. Student account ledger 2. COD system records 4. Quality Assurance Reviews 1. Supervisor approval required prior to COD reporting Timeline: Process corrections implemented in Fall 2025; Full compliance expected by June 30, 2026 Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884
2024-004
FAC accepted this audit on February 19, 2025 — management decision was due August 19, 2025.
The College could not timely retrieve all student records and show documentation of reviews and approvals. Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR. Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals. Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements. Effect: The College cannot show appropriate documentation for all records and controls. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Show full finding ▾Hide full finding ▴Significant Deficiency Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements. Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals. Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR. Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals. Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements. Effect: The College cannot show appropriate documentation for all records and controls. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely retrieval of all student records and the proper documentation of reviews and approvals to meet regulatory requirements and to improve accountability in the Student Financial Aid Cluster. Corrective Actions: To address the conditions and ensure compliance with regulations, the following corrective actions will be taken: A. Improvement of Student Record Retrieval Process: • Upgrade and/or streamline systems used for storing and retrieving student records. • Conduct an audit of existing data storage systems to identify inefficiencies, technical glitches, or areas for improvement. • Implement an automated system for flagging and retrieving missing or incomplete records in real-time. B. Enhanced Documentation of Reviews and Approvals: • Revise and reinforce the process for documenting reviews and approvals for all student records, ensuring that every step is appropriately tracked and stored. • Implement a centralized digital approval system to reduce paperwork and ensure easier tracking of approvals. C. Staff Training and Awareness: • Provide comprehensive training for all staff involved in financial aid processing on the importance of timely record retrieval and proper documentation of reviews and approvals. • Implement periodic refresher courses for staff, with a focus on improving accuracy in the review and approval process. D. Enhanced Communication and Coordination: • Establish a cross-functional team responsible for monitoring the status of student records, identifying delays, and ensuring approvals are documented. • Create an internal tracking system for ensuring the timely completion of records reviews and approvals. Monitoring and Follow-Up: To ensure that the corrective actions are being implemented effectively, the College will engage in internal reporting (monthly), external audit (annually), and a third-party review (annually) Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: April 30, 2025
The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions. Context: Of our population tested the College had six status changes to the NSLDS after 60 days. Effect: The College did not report status changes to the NSLDS timely. Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Show full finding ▾Hide full finding ▴Nonmaterial Noncompliance Findings Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Compliance Requirement: Special Test and Provisions – Enrollment Reporting Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change. Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions. Context: Of our population tested the College had six status changes to the NSLDS after 60 days. Effect: The College did not report status changes to the NSLDS timely. Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS. Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: 1. Review and update internal policies and procedures 2. Training and education for relevant staff 3. Implement a tracking and monitoring system 4. Conduct regular audits and monitoring 5. Collaborate with NSLDS for support and guidance Monitoring and Follow-Up: • The College’s Financial Aid Office will track the implementation of this Corrective Action Plan and provide monthly progress updates to senior management. • The College will conduct periodic reviews and evaluations to ensure that the plan’s objectives are being met and that the institution remains in full compliance with the Department of Education’s reporting requirements. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: February 28, 2025
The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024. Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy. Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy. Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against. Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b). Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Show full finding ▾Hide full finding ▴Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b). Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024. Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy. Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy. Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against. Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b). Management Response: The College concurs with this finding. Corrective Action Plan: See attached management’s corrective action plan.
Finding 2024-003 Student Financial Aid Cluster, CFDA # 84.007, 84.033, 84.063, 84.268 Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024. Corrective Action Plan: Objective: To ensure the development and implementation of a written Student Information Security Plan. Corrective Actions: 1. Develop and implement a written security program in line with the requirements outlined within 16 CFR 314.4 (b) 2. Assign a Security Program Manager and conduct a risk assessment 3. Update and enforce data security policies Monitoring and Follow-Up: • The College’s Security Program Manager will be responsible for ensuring the implementation of the CAP and will provide monthly progress reports to senior management. • Regular internal audits will assess compliance with the security program, with any necessary updates or changes implemented in a timely manner. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: February 28, 2025
The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system. Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system. Context: Of the population tested all the disbursement dates in the COD system did not match student records. Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system. Management Response: The College concurs with this finding.
Show full finding ▾Hide full finding ▴Nonmaterial Noncompliance Findings Finding 2024-004 - Student Financial Aid Cluster, CFDA# 84.063, 84.268 Compliance Requirement: Reporting Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system. Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system. Context: Of the population tested all the disbursement dates in the COD system did not match student records. Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system. Management Response: The College concurs with this finding.
Finding 2024-004 Student Financial Aid Cluster, CFDA # 84.063, 84.268 Condition: The College did not report the actual disbursement date that students receive the Direct Loan and/or Pell Funds to the COD system. Corrective Action Plan: Objective: To ensure the Financial Aid office reports the actual disbursement date the student receives the Direct Loan and/or Pell funds to the COD system. Corrective Actions: 1. Establish a Standard Operating Procedure (SOP) for reporting disbursement dates 2. Implement an automated system for disbursement reporting 3. Training for Financial Aid and Accounting staff 4. Coordination between relevant departments 5. Verification and reconciliation process 6. Review and monitor data submissions 7. Establish a process for correcting disbursement errors 8. Ongoing monitoring and follow-up Monitoring and Follow-Up: The Financial Aid Office will be responsible for ensuring the implementation of this corrective action plan and will provide monthly updates to senior management. Person(s) Responsible for Corrective Action Plan: Jamieta Hoskins, Director of Financial Aid Anticipated Completion Date for Corrective Action Plan: March 31, 2025
FAC accepted this audit on January 11, 2024 — management decision was due July 11, 2024.
FAC accepted this audit on March 5, 2024 — management decision was due September 5, 2024.
FAC accepted this audit on March 14, 2023 — management decision was due September 14, 2023.
When gaining an understanding of the College's procurement procedures, we noted that the College could not support if there was a documented procurement policy in place during fiscal year 2022. Criteria: Title 2, Subtitle A, Chapter II, Part 200, Subpart D, ?200.318, states that the auditee must have and use documented procurement procedures for the acquisition of property or services required under Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?200.317 through ?200.327. Questioned Costs: None Effect: The College does not properly maintain a documented procurement policy in accordance with Title 2, Subtitle A, Chapter II, Part 200, Subpart D, ?200.318. Cause: Inadequate internal control over the existence of a formal procurement policy implemented by the College. Recommendation: We recommend that the College formally adopt a procurement procedures document to ensure the applicable procurement requirements are adhered to and supported. Management's Response: A procurement policy was formally approved by the Board of Trustees of the College on February 23, 2023.
Show full finding ▾Hide full finding ▴Condition: When gaining an understanding of the College's procurement procedures, we noted that the College could not support if there was a documented procurement policy in place during fiscal year 2022. Criteria: Title 2, Subtitle A, Chapter II, Part 200, Subpart D, ?200.318, states that the auditee must have and use documented procurement procedures for the acquisition of property or services required under Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?200.317 through ?200.327. Questioned Costs: None Effect: The College does not properly maintain a documented procurement policy in accordance with Title 2, Subtitle A, Chapter II, Part 200, Subpart D, ?200.318. Cause: Inadequate internal control over the existence of a formal procurement policy implemented by the College. Recommendation: We recommend that the College formally adopt a procurement procedures document to ensure the applicable procurement requirements are adhered to and supported. Management's Response: A procurement policy was formally approved by the Board of Trustees of the College on February 23, 2023.
2022-001 - Procurement Policy Recommendation: The auditors recommended that the College formally adopt a procurement procedures document to ensure the applicable procurement requirements are adhered to and supported. Actions Taken or Planned: A procurement policy was formally approved by the Board of Trustees of the College on February 23, 2023. Person Responsible: Matt Gawenda, Dean of Finance Estimated Date of Completion: February 23, 2023
FAC accepted this audit on March 14, 2022 — management decision was due September 14, 2022.
FAC accepted this audit on March 15, 2021 — management decision was due September 15, 2021.
FAC accepted this audit on November 11, 2019 — management decision was due May 11, 2020.
FAC accepted this audit on November 4, 2018 — management decision was due May 4, 2019.
FAC accepted this audit on November 12, 2017 — management decision was due May 12, 2018.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on October 19, 2016 — management decision was due April 19, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-002
GSA_MIGRATION
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GSA_MIGRATION
2015-003
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