Скачать презентацию Food Assistance Division FAD 1250 Maryland Avenue S Скачать презентацию Food Assistance Division FAD 1250 Maryland Avenue S

44c146fb603372b34f442aa672ad4832.ppt

  • Количество слайдов: 75

Food Assistance Division (FAD) 1250 Maryland Avenue, S. W. Suite 400 Washington, D. C. Food Assistance Division (FAD) 1250 Maryland Avenue, S. W. Suite 400 Washington, D. C. 20024 1

Food Assistance Division Who We Are DIRECTOR’S OFFICE (General Budget, Program Regulations, Local Regional Food Assistance Division Who We Are DIRECTOR’S OFFICE (General Budget, Program Regulations, Local Regional Procurement, Cash Disbursements, etc. ) NAME TELEPHONE Ron Croushorn, Director Babette Gainor, Deputy Director Brian Goggin, Deputy Director Ida Larmore, Secretary Joyce Friedenberg, Ag Economist William Whelan, Ag Economist Faye Johnson, Ag Marketing Assistant FAX: 202 -690 -0251 202 -720 -3038 202 -690 -2543 202 -720 -2637 202 -720 -4221 202 -720 -6734 202 -401 -0157 202 -720 -7515 TRANSPORTATION & LOGISTICS BRANCH (Freight & Commodity Concerns, Food Aid Quality, Documentation, etc. ) NAME TELEPHONE Tim Powers, Branch Chief (TDY) Amy Harding, Traffic Management Specialist Ed Roseberry, Traffic Management Specialist Jamie Fisher, Program Analyst Karen Hoag, Program Specialist 202 -720 -6334 202 -720 -3538 202 -720 -0382 202 -720 -5620 202 -720 -9421 FAX: 202 -690 -0251 2

Food Assistance Division Who We Are SCHOOL FEEDING & HUMANITARIAN BRANCH (MCGOVERN-DOLE INTERNATIONAL FOOD Food Assistance Division Who We Are SCHOOL FEEDING & HUMANITARIAN BRANCH (MCGOVERN-DOLE INTERNATIONAL FOOD FOR EDUCATION AND CHILD NUTRITION & SECTION 416(b) PROGRAMS) NAME/REGIONAL RESPONSIBILITY TELEPHONE FAX: 202 -690 -3078 Dorothy Feustel, Branch Chief 202 -720 -0150 Richard Chavez, Sr. Program Analyst-Latin America and Middle East 202 -401 -0100 Alessandra Mc. Cormack, Program Analyst-Asia and WFP 410 -519 -0845 Mark Myers, Sr. Program Analyst-Africa 202 -401 -0129 FOOD FOR DEVELOPMENT BRANCH (FOOD FOR PROGRESS & TITLE I PROGRAMS) NAME/REGIONAL RESPONSIBILITY Judy Phillips, Branch Chief Erika Beltran, Program Analyst-Latin America Abdullah (Al) Ersoz, Program Analyst-Southern Africa Debbie Pfaff, Sr. Program Analyst, Western Africa Nicola Sakhleh, Sr. Program Analyst-Asia and Europe Bill Verzani-Eastern, Program Analyst- Africa/Middle East TELEPHONE FAX: 202 -690 -0251 202 -720 -0732 202 -720 -5263 202 -720 -3405 202 -720 -9434 202 -720 -4228 202 -720 -5453 3

SFHB and FFDB Responsibilities n n Review and Evaluate Proposals Develop Agreements & Amendments SFHB and FFDB Responsibilities n n Review and Evaluate Proposals Develop Agreements & Amendments Review Logistics and Monetization & Financial Reports Liaison between PVO and FAS 4

Subrecipients & Subagreements Subrecipient § A legal entity that receives donated commodities, income, sale Subrecipients & Subagreements Subrecipient § A legal entity that receives donated commodities, income, sale proceeds or other resources from a Participant for the purpose of implementing activities in the targeted country § A Subrecipient may be a foreign (local) or international organization Approval § FAS approval is required 5

Subagreements n Participants enter into a written Subagreement with each subrecipient § Copies of Subagreements n Participants enter into a written Subagreement with each subrecipient § Copies of all Subagreements must be submitted to FAS § Subagreements will stipulate the responsibilities of each party § Subrecipient is accountable to the Participant. § Participants are responsible for monitoring the actions of their Subrecipients as necessary to ensure that donated commodities or resources are used for authorized purposes in compliance with applicable laws and regulations and the agreement and that performance goals are achieved 6

Operating in Host Country § Proposal must address applicant’s ability to become registered and Operating in Host Country § Proposal must address applicant’s ability to become registered and operate in targeted country § Registration methods vary throughout the world. Check for requirements in each country § Contact FAS Attaché or Embassy if unaware of registration process in host country www. fas. usda. gov/scriptsw/fasfield/ovs_directory_search. asp § Registration verification is required prior to Agreement signing 7

Bank Accounts Participant Responsibilities Participant shall deposit all sale proceeds and income into a Bank Accounts Participant Responsibilities Participant shall deposit all sale proceeds and income into a separate, interest-bearing account Exceptions will only be made if the account is in a country where the laws and customs prohibit the payment of interest, or FAS determines that this requirement would constitute an undue burden 8

Bank Accounts Supervision and disbursements § An appropriate Participant official must supervise each account Bank Accounts Supervision and disbursements § An appropriate Participant official must supervise each account and must approve all disbursements from the account Full Accounting § Full accounting of funds must be maintained by the Participant 9

Budget Management Proposed Budget § Detailed budget (negotiating tool) Agreement Budget § Summary Budget Budget Management Proposed Budget § Detailed budget (negotiating tool) Agreement Budget § Summary Budget (legally binding) 10

Changes to the Agreement Two types of changes § Textual changes § Budget changes Changes to the Agreement Two types of changes § Textual changes § Budget changes 11

Amendments § An amendment is required when items stated in the signed agreement need Amendments § An amendment is required when items stated in the signed agreement need to be changed § Examples § § Geographic location Activities/projects Level of actual proceeds realized Reallocations of funds beyond the flexibility in the signed agreement § The agreement must be amended BEFORE taking any action § Discuss the proposed amendment with FAD staff 12 § You can e-mail a copy to the analyst

Amendments Written amendment request § A written amendment request must be submitted with Participant’s Amendments Written amendment request § A written amendment request must be submitted with Participant’s official signature Amendment request should include: § § A brief explanation of requested changes A revised version of the agreement text which identifies all sections that would have to be changed 13

Budget Realignment § A Budget realignment is required when adjustments in budget line items Budget Realignment § A Budget realignment is required when adjustments in budget line items exceed $50, 000 or 20 percent of total administrative budget § Older agreements have less flexibility with adjustments § $1, 000 or 10 percent, whichever is less § $5, 000 or 20 percent, whichever is less § $35, 000 or 20 percent, whichever is less § Please see your agreement for details 14

Budget Realignment Instructions located at: www. fas. usda. gov/excredits/Food. Aid/budget/amndinst. html Changing budget format Budget Realignment Instructions located at: www. fas. usda. gov/excredits/Food. Aid/budget/amndinst. html Changing budget format or formulas! 15

Amendments: Factors that Affect Requests §Submitted in proper format §Reasonable administrative increases §No violation Amendments: Factors that Affect Requests §Submitted in proper format §Reasonable administrative increases §No violation has occurred §Activities still on-going §Benefit to program §No financial harm to CCC/FAS 16

Amendments Send official request to: Director, Food Assistance Division Foreign Agricultural Service/USDA Ag. STOP Amendments Send official request to: Director, Food Assistance Division Foreign Agricultural Service/USDA Ag. STOP 1034 1400 Independence Avenue, SW Washington, DC 20250 -1034 (Preferred Address) 1250 Maryland Avenue, SW Suite 400 Washington, DC 20024 17

Amendments Official Amendment becomes official once signed by FAS, and Participant may implement its Amendments Official Amendment becomes official once signed by FAS, and Participant may implement its provisions 18

Funds Management Cash Advance/Reimbursement Return of Funds All forms and instructions can be found Funds Management Cash Advance/Reimbursement Return of Funds All forms and instructions can be found on the FAS website under Mc. Govern-Dole and Food for Progress http: //www. fas. usda. gov/food-aid. asp 19

Cash Request Guidelines n n n Cash requests should be made using the appropriate Cash Request Guidelines n n n Cash requests should be made using the appropriate form and submitted to FAD Please be sure that all required financial reports have been submitted to FAD prior to requesting cash (advance or reimbursement). Reports may be submitted by email along with the cash request if reporting is not up to date. Ophelia. Johnson@fas. usda. gov PPDED@fas. usda. gov Reimbursements n n A participant may request the payment of CCC/FAS provided funds to reimburse it for authorized expenses These expenses must be shown as obligations on the Participant’s latest financial report 20

Cash Advances n n Mc. Govern-Dole and Food for Progress (new regulations) n 100% Cash Advances n n Mc. Govern-Dole and Food for Progress (new regulations) n 100% of funds may be advanced n All interest earned on advanced funds must be returned to CCC/FAS will not approve any request for an advance if: (i) It is received earlier than 60 days after the date of a previous advance made in connection with the same agreement; or (ii) Any required reports, as specified in § 1499. 13 and in the agreement, are more than six months in arrears. 21

Cash Request Flow Program Participant (e. g. PVO) USDA/CCC FAD Office of the Director Cash Request Flow Program Participant (e. g. PVO) USDA/CCC FAD Office of the Director USDA/FSA Financial Mgt Division Email Request for Agreement Funds Edited Email Request for Agreement Funds (if necessary) Signed Official Request for Agreement Funds Wire Transfer 3 0 d a y s Wire Transfer 22

http: //www. fas. usda. gov/food-aid. asp 23 http: //www. fas. usda. gov/food-aid. asp 23

24 24

25 25

26 26

27 27

Cash Advance/Reimbursement Mailing Addresses Mail the signed official cash advance/reimbursement request letter via courier Cash Advance/Reimbursement Mailing Addresses Mail the signed official cash advance/reimbursement request letter via courier (DHL, UPS, Fed. Ex, etc. ), preferred method, to: USDA/FAS/Office of Capacity Building and Development/Food Assistance Division / Office of the Director / Attn: Faye Johnson The Portals Building 1250 Maryland Avenue, SW Suite 400 Washington, DC 20024 Phone: (202) 720 -4221 or via U. S. Postal Service USDA/FAS/Office of Capacity Building and Development/Food Assistance Division/ Office of the Director / Attn: Faye Johnson Ag Stop 1034 1400 Independence Ave, SW Washington, DC 20050 Phone: (202) 720 -4221 [If you choose to use the U. S. Postal Service, please note that mail coming into USDA can be delayed more than 30 days due to security measures. ] 28

Return of Funds n n n Unobligated advances Interest Earned under Mc. Govern-Dole Additional Return of Funds n n n Unobligated advances Interest Earned under Mc. Govern-Dole Additional proceeds not authorized for use Other unspent funds Please email a “return of funds” form to FAS before sending check or wire Ophelia. Johnson@fas. usda. gov PPDED@fas. usda. gov n Wire Transfer is preferred method (faster, safer, easily traceable) 29

Forms can be found at: 30 Forms can be found at: 30

Return of funds by wire transfer 31 Return of funds by wire transfer 31

Return of funds by check 32 Return of funds by check 32

Funds Management Help For additional information or assistance, please contact Faye Johnson at 202 Funds Management Help For additional information or assistance, please contact Faye Johnson at 202 -720 -7515 (OPHELIA. JOHNSON@FAS. USDA. GOV ) or the Division Office at 202 -720 -4221. n 33

Freight Forwarder Assignment n n n When a freight forwarder is used, the participant Freight Forwarder Assignment n n n When a freight forwarder is used, the participant will notify FAS/FAD If requested, FAD/TLB will provide a list of freight forwarders who have participated in food assistance programs in the past The participant shall provide Director, FAS/FAD certification that the freight forwarder is compliant with § 1499. 7(c) and § 1599. 7(c) of the Food for Progress and Mc. Govern-Dole regulations 34

Commodity Invitation n n The freight forwarder, on behalf of the participant, or the Commodity Invitation n n The freight forwarder, on behalf of the participant, or the participant, enters commodity requests (call forward) into FARES TLB reviews the FARES call forward data and routes to KCCO prepares the commodity purchase invitation Packaged and processed commodity invitations are issued monthly Bulk commodity invitations are issued on an asrequested basis 35

Freight Invitation n Options for freight contracting under the new regulations n n n Freight Invitation n Options for freight contracting under the new regulations n n n USDA will issue FAR compliant freight invitations The participant, in accordance with the process specified in the agreement, will acquire freight All freight contracts must meet cargo preference requirements 36

Commodity and Freight Purchase n In cases where USDA procures commodity and freight, the Commodity and Freight Purchase n In cases where USDA procures commodity and freight, the KCCO Commodity Operations System performs the lowest landed cost evaluation and generates an optimal solution n The option to purchase other than on the lowest landed cost basis exists in the FAR FAD reviews the recommended solution and assures it is within budget levels TLB provides concurrence to KCCO to purchase commodity and freight 37

Reporting Requirements (Where To Find) n n n Agreement Rules and Regulations -7 CFR Reporting Requirements (Where To Find) n n n Agreement Rules and Regulations -7 CFR Part 1499 (Food For Progress) -7 CFR Part 1599 (Mc. Govern-Dole) -7 CFR Part 3019 (USDA-wide) FAS Personnel 38

Reports Applicable When Due Program Logistics & Monetization FFE & FFP Semi-annually (as specified Reports Applicable When Due Program Logistics & Monetization FFE & FFP Semi-annually (as specified in agreement) Project Status FFE Semi-annually (as specified in agreement) USDA/CCC Financial FFE & FFP Quarterly – based on calendar year Audit FFE & FFP Annually Reporting Forms and Audit Information May Be Found At: http: //www. fas. usda. gov/excredits/Food. Aid/budget/food%20 for%20 progress%20 budgets. html http: //www. fas. usda. gov/excredits/Food. Aid/budget/food%20 for%20 education%20 budgets. html 39

Reporting Tips n n n Submit timely & accurate reports Complete all applicable sections Reporting Tips n n n Submit timely & accurate reports Complete all applicable sections Verify all numbers i. e. tonnages & dollars Report against objectives and indicators in the agreement Seek assistance (Program Analyst) if uncertain Respond to inquiries in a timely manner 40

Reports Help To: n n n Monitor progress against objectives and indicators in the Reports Help To: n n n Monitor progress against objectives and indicators in the agreement Ensure funds are being used properly and in accordance with the agreement budget Bring awareness to problems, issues, and challenges Provide a picture on how agreement is progressing Evaluate agreement at time of closeout 41

New Developments n n Interim and Final Evaluations (New Rules and Regulations) FAS is New Developments n n Interim and Final Evaluations (New Rules and Regulations) FAS is reviewing report forms following publications of new Rules and Regulations 42

Submitting Reports Please send hard copy via courier to: USDA/FAS/Office of Capacity Building and Submitting Reports Please send hard copy via courier to: USDA/FAS/Office of Capacity Building and Development Director – Food Assistance Division 1250 Maryland Avenue, SW Suite 400 Washington, DC 20024 via U. S. Postal Service USDA/FAS/Office of Capacity Building and Development Director – Food Assistance Division Ag Stop 1034 1400 Independence Ave, SW Washington, DC 20050 *E mail copy to: PEBReports@fas. usda. gov 43

Success Stories n n Food Aid improves the lives of people throughout the world, Success Stories n n Food Aid improves the lives of people throughout the world, yet many do not get the chance to personally see the tremendous impact of its work or meet the individuals, families, and communities who benefit from American assistance. Food Aid Success Stories are an effort to let everyone see the impact of Food Aid’s work and meet the people whose lives it changed – it is also their effort to say “thank you” for America’s help. 44

Success Stories may include: n n n Impact of food aid on individuals, communities, Success Stories may include: n n n Impact of food aid on individuals, communities, governments, etc… Number of meals served and nutritional benefits realized Beneficiaries of buildings/schools constructed Increase in productivity due to irrigation systems built Income generated Number of jobs created 45

Success Stories n To submit a story review the Guidelines provided at the following Success Stories n To submit a story review the Guidelines provided at the following website: http: //www. fas. usda. gov/Food. Aid. Stories/Story. aspx. n Please submit the following types of stories: n n n Success Story Provides a detailed overview of a program, illustrated by a powerful photograph. First Person Focuses on one person who benefited from a program or worked with Food. Aid to create change in the community, including a background paragraph and a quote from and picture of the subject. Photo and Caption Uses a powerful photo and succinct caption to illustrate how Food Aid is making a difference, along with two or three paragraphs of text to provide background. 46

Uses of Success Stories n n n The Mc. Govern-Dole Congressional Report The International Uses of Success Stories n n n The Mc. Govern-Dole Congressional Report The International Food Assistance Report The U. S. Overseas Loans & Grants Report U. S. Annual Aid Review Other Reports to Congress General Public Awareness 47

Benefits of Success Stories n n Funding Support Appreciation Acceptance 48 Benefits of Success Stories n n Funding Support Appreciation Acceptance 48

A-133 Audit “Helping to Build a Sustainable Culture of Program Accountability and Transparency ” A-133 Audit “Helping to Build a Sustainable Culture of Program Accountability and Transparency ” Barbara Shumar, Senior Analyst, OCBD 49

A-133 Audit Discussion Overview of A-133 Audits Program participant responsibilities Helpful websites 50 A-133 Audit Discussion Overview of A-133 Audits Program participant responsibilities Helpful websites 50

OMB Circular A-133 Audits n n Participants are required to perform an audit to OMB Circular A-133 Audits n n Participants are required to perform an audit to assure compliance to the program agreements and regulations If a Participant provides more than $25, 000 to a recipient agencies this agency must also have an audit 51

OMB Circular A-133 Audits n n All non-Federal organizations that expend $500, 000 or OMB Circular A-133 Audits n n All non-Federal organizations that expend $500, 000 or more of Federal awards in a year are required to obtain an annual audit Organizations expending less than $500, 000 in a year are exempt from the Federal audit requirements, but must make records available for review or audit 52

OMB Circular A-133 Audits n Participants can request funds to cover the cost of OMB Circular A-133 Audits n Participants can request funds to cover the cost of the audit in their proposal submission to the Food Assistance Division 53

Responsibilities of Participant Under OMB Circular A-133 n n n Identify Federal awards received Responsibilities of Participant Under OMB Circular A-133 n n n Identify Federal awards received and expended Prepare financial statements and a Schedule of Expenditures of Federal Awards Obtain an auditor 54

Responsibilities of Participant Under OMB Circular A-133 n n Ensure completion of audit Submit Responsibilities of Participant Under OMB Circular A-133 n n Ensure completion of audit Submit the audit reporting package and Data Collection Form (form SF-SAC) to the Federal Clearinghouse within 9 months from the end of your fiscal year 55

Responsibilities of Participant Under OMB Circular A-133 n In addition to submitting a copy Responsibilities of Participant Under OMB Circular A-133 n In addition to submitting a copy of your OMB Circular A-133 Audits to the Federal Clearing House audits, both OMB Circular A-133 and agreement audits must also be provided directly to: Ronald Croushorn Director, Food Assistance Division 1250 Maryland Ave, SW Suite 400 Washington, DC 20024 56

Audit Findings n n n Audits are reviewed for findings If a Participant has Audit Findings n n n Audits are reviewed for findings If a Participant has findings, ME&S will contact the participant regarding their corrective action plan If the next year audit continues to have findings or shows no improvement, ME&S may request a meeting with you and your accounting staff 57

Helpful Websites n n n http: //www/whitehouse. gov/omb/circul ars/a 133. htm http: //harvester. census. Helpful Websites n n n http: //www/whitehouse. gov/omb/circul ars/a 133. htm http: //harvester. census. gov/fac/2008 SA QA/htm http: //georgewbushwhitehouse. archives. gov/omb/circulars/ a 133_compliance/08/usda. pdf 58

OCBD Food Aid Closeout “Helping to Build a Sustainable Culture of Program Accountability and OCBD Food Aid Closeout “Helping to Build a Sustainable Culture of Program Accountability and Transparency ” Barbara Shumar, Senior Analyst, OCBD 59

Closeout Discussion Overview n n Agreement closeout priorities Indicators of closeout readiness Documents needed Closeout Discussion Overview n n Agreement closeout priorities Indicators of closeout readiness Documents needed for closure Closeout process 60

CLOSEOUT n For Pre 2002 agreements the Monitoring and Evaluation Staff is responsible for CLOSEOUT n For Pre 2002 agreements the Monitoring and Evaluation Staff is responsible for ensuring that all documents have been provided by the Participants and closing the agreements 61

CLOSEOUT n For Post 2001 agreements the Food Assistance Division will work with the CLOSEOUT n For Post 2001 agreements the Food Assistance Division will work with the Participants to ensure that all relevant reports and documents have been submitted. Once the Food Assistance Division has made that determination, the agreement will be provided to the Monitoring and Evaluation Staff for closure 62

CLOSEOUT n An agreement is ready for closeout: n n n activities have been CLOSEOUT n An agreement is ready for closeout: n n n activities have been completed in most cases, all commodities have been distributed, all monetization proceeds and cash provided have been spent 63

CLOSEOUT n n Final, cumulative logistics and monetization (log/mon) report received Final, cumulative financial CLOSEOUT n n Final, cumulative logistics and monetization (log/mon) report received Final, cumulative financial report received any funds that were advanced but not spent returned to USDA 64

CLOSEOUT n n n List of equipment purchased over $5, 000 and how you CLOSEOUT n n n List of equipment purchased over $5, 000 and how you intend to dispose of equipment All relevant tax certification information received and accepted Copies of all relevant audits and any issues related to the agreement resolved 65

M&ES’s Closeout Process n n M&ES prepares a written evaluation regarding each agreement closed M&ES’s Closeout Process n n M&ES prepares a written evaluation regarding each agreement closed Information to complete this evaluation is gathered from the Logistics and Monetization Report, Financial Reports, the signed agreement, and any amendments 66

M&ES’s Closeout Process n n Once the written evaluation is completed, a closeout letter M&ES’s Closeout Process n n Once the written evaluation is completed, a closeout letter is drafted The closeout letter may inform you that you have completed all of the requirements under the agreement and USDA considers the agreement closed 67

M&ES’s Closeout Process n n The letter may inform you that you are eligible M&ES’s Closeout Process n n The letter may inform you that you are eligible for the CCC funds that remain from the cash grant you received and ask you to request the funds In some instances, we may determine that you need to reimburse USDA and request that you return the funds within 30 days 68

Closeout Checklist The website for the closeout checklist: http: //www. fas. usda. gov/excredits/Food Aid/budget/food%20 Closeout Checklist The website for the closeout checklist: http: //www. fas. usda. gov/excredits/Food Aid/budget/food%20 for%20 progress% 20 budgets. html n 69

FAS’ Compliance Role in Food Aid Agreements Steven Rhodes, Director CSEPD 4/6/2009 70 FAS’ Compliance Role in Food Aid Agreements Steven Rhodes, Director CSEPD 4/6/2009 70

Compliance, Security and Emergency Planning Division (CSEPD) § Staff of 13 conducting cooperator and Compliance, Security and Emergency Planning Division (CSEPD) § Staff of 13 conducting cooperator and food aid reviews, OIG/GAO liaison and security/investigations § Conduct 4 to 5 Financial and Compliance Reviews annually of CCC/USDA food aid agreements (selected/random) § Separate from OMB A-133 requirements 71

 Items for Your Radar Document, Transparent, Traceable Reporting § Traceable Logistics and Monetization Items for Your Radar Document, Transparent, Traceable Reporting § Traceable Logistics and Monetization Reports § Reasonable, procurement practices (document process) § Complete final reporting (log. Mon. / Financial Reports) CCC Advances § Must be in interest bearing account § Account traceable to individual agreements 72

Items for Your Radar (cont. ) Monetization § In accordance with the agreement (transparent) Items for Your Radar (cont. ) Monetization § In accordance with the agreement (transparent) § Demonstrate fair solicitation/sale § Enforce terms of sales contract Contracting § Ensure comprehensive agreement with recipient organization (subrecipient) is in place 73

Items for Your Radar (cont. ) Damage/Loss of commodity § Make reasonable effort to Items for Your Radar (cont. ) Damage/Loss of commodity § Make reasonable effort to pursue collection (report to FAS) § Settlement for less than full amount requires FAS approval Questions Regarding what/how to report? § Contact FAS’ Food Assistance Division 74

CSEPD Compliance Staff § Beth Wong Compliance Review Officer 202 -690 -1041 § Lawrence CSEPD Compliance Staff § Beth Wong Compliance Review Officer 202 -690 -1041 § Lawrence Chamorro, Compliance Review Spec. 202 -720 -0575 § Jameika Henderson, Compliance Review Spec. 202 -690 -4097 § Jennifer Duncan, Compliance Review Spec. 202 -690 -1154 § Marianne Soliman, Compliance Review Spec. 202 -720 -8894 § Kesha Pitt, Compliance Review Spec. 202 -720 -9180 75