Disaster Assistance Loans

High-priority program

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Program level Payment Integrity results

Sponsoring agency: Small Business Administration

View on Federal Program Inventory

PROGRAM METRICS

$545 M

in FY 2021 outlays, with a

86.6%

payment accuracy rate

PROGRAM METRICS

$1,134 M

in FY 2022 outlays, with a

96.9%

payment accuracy rate

PROGRAM METRICS

$872 M

in FY 2023 outlays, with a

96.1%

payment accuracy rate

PROGRAM METRICS

$1,176 M

in FY 2024 outlays, with a

96.4%

payment accuracy rate

PROGRAM METRICS

$3,224 M

in FY 2025 outlays, with a

95.1%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2021 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2020 - 03/2021


    Confidence interval:

    >95%


    Margin of error:

    +/-3.0

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $31.65 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $31.65 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $41.19 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.45 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $40.74 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$41.19 M

Unknown Payment Details

Evaluation of corrective actions

1) Require all training materials be reviewed and approved by SBA headquarters.
Expanding training efforts to include one-on-one training with Application Processing Team Leads; and
2) Require all departments performing any form of quality assurance/control checks to report their findings monthly inclusive of:
The specific loan data,
- loan numbers
- amounts
- issues uncovered
· Tracking and resolution of uncovered issues
· Provide monthly summary report to the Quality Control Supervisor
3) Conduct bi-monthly improper payment meetings that includes all teams responsible for ODA quality assurance/control. Meeting should have a written agenda and meeting minutes to capture the development

Future payment integrity outlook

Disaster Assistance Loans has established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $544.98 M
Current year +1 estimated future improper payments $72.84 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 13.37 %

The program's current year improper payment and unknown payment rate of 13.37 % has been achieved with a balance of payment integrity risk and controls and represents the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is the tolerable rate.

Currently, the agency has what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce IPs and UPs to the tolerable rate and statutory rate.

Additional programmatic information

  • FY 2022 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2021 - 03/2022


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

Overpayments

Statutory Requirements of Program were not met due to loan processor errors.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $15.65 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $15.65 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $6.6 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $6.6 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Technically improper payments

Primary source of Improper payments for Technically Improper Payments were: -Loan conditions not met; -Vehicle registration missing; and, -Failure to confirm fair days rental in accordance with Standard Operating Procedures.
The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $12.44 M

Additional information

$19.04 M

Unknown Payment Details

Evaluation of corrective actions

The FY 2022 improper payment rate estimate of 3.06 percent for this program is less than the target reduction rate of 3.71 percent from FY 2021. SBA revised its corrective action process in FY 2022. Corrective actions, which typically include obtaining supporting documentation from the borrower, are completed within 15 days of being informed of the improper payment. In addition, SBA provides quarterly training to loan approval staff on the causes of and prevention of improper payments.

Collection efforts continue at the Disaster loan servicing centers, but if these efforts fail, the borrower will still be liable for the over-disbursed amount in the form of monthly payments in accordance with the loan agreement. Thus, any actual loss is the cost of funds related to the over disbursement.

Future payment integrity outlook

Disaster Assistance Loans has established a baseline.

The FY 2022 improper payment rate estimate of 3.06 percent for this program is less than the target reduction rate of 3.71 percent from FY 2021. Because of the reduction in the improper payment rate, the Disaster Assistance Loan program is considered to have met its reduction target. For FY 2023, the SBA established a reduction target of 2.96 percent for the Disaster Assistance Loan program.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $1,133.59 M
Current year +1 estimated future improper payments $33.55 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 2.96 %
Current year +1 estimated future improper payment and unknown payment reduction target 2.96 %

The program's current year improper payment and unknown payment rate of 3.06 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

In FY 2022, the SBA refined the improper payment review procedures to ensure only payments that are truly improper are identified as improper. As such, the SBA does not have sufficient historical data to determine an acceptable tolerable rate for this program.

The agency has what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce improper payments and unknown payments to the tolerable rate.

No resources were requested in the most recent budget submission of the agency to establish and maintain the internal controls.

Additional programmatic information

Payment integrity related information has been captured through the survey.

  • FY 2023 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2022 - 03/2023


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    Corrective actions may include but is not limited to obtaining supporting documentation from the borrower, completing a loan modification, and/or adding clarifying comments to a file; corrective actions are to be completed within 15 days of the final improper payment decision. The SBA provides quarterly training to PDC staff on the causes and prevention of, improper payments.
    FY2023 Q4
    Completed
    Audit
    The Disaster Internal Control Division (DICD) conducts quality assurance reviews on an ongoing basis to identify areas where additional training of the PDC Departments may be necessary, and as a preventative measure to reduce potentially improper payments.
    FY2023 Q4
    Completed
    Automation
    SBA is currently in the process of developing a new unified lending platform, which is heavily based on automation of the loan making process.
    FY2025
    Planned
    Training
    Per Numbered Memo 22-04, training specific to Improper Payment Audit findings is required on an ongoing basis.
    FY2024
    Planned
    Audit
    Per Numbered Memo 22-04, the Disaster Internal Controls Division is required to perform quality control and quality assurance audits on an ongoing basis.
    FY2024
    Planned

Overpayments

The overall root cause of overpayments was failure to access data/information needed. The most prevalent cause of improper payments stemmed from improper accounting of verified losses on disaster-damaged property, duplication of benefits not adequately addressed, misallocation of loan funds, and improper calculation of economic injury. Corrective actions may include but are not limited to obtaining supporting documentation from the borrower, competing a loan modification, and/or adding clarifying comments to the case file. In addition, SBA provides reoccurring training to staff on causes and prevention of improper payments.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $33.13 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $33.13 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Financial $16.57 M
Overpayments Within Agency Control Receiving Benefits from Other Sources $16.57 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Audit, Training Audit, Automation, Training

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $1.16 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $1.16 M

Eligibility element/information needed Eligibility amount
Financial $1.16 M

Mitigation strategies taken Mitigation strategies planned
Audit, Training Audit, Automation, Training

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$1.16 M

Unknown Payment Details

Evaluation of corrective actions

The planned automation through the new unified lending platform will implement business rules directly related to eligible recipient and eligible amount. In addition, it will utilize third party verification to confirm eligibility. The ongoing training and corrective actions required by Numbered Memo 22-04 address current areas of concerns, allowing the PDC trainings to focus on identified areas. The certification required by Numbered Memo 22-04 the PDC and Center Director establish accountability for trainings and corrective actions.

Future payment integrity outlook

Disaster Assistance Loans has established a baseline.

The reduction target represents a .10% decrease from the prior year's improper payment rate, which is anticipated due to automation, training, and corrective actions plan. The training and corrective actions are required by Numbered Memo 22-04.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $1,350.11 M
Current year +1 estimated future improper payments $51.71 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 3.83 %
Current year +1 estimated future improper payment and unknown payment reduction target 3.83 %

The program's current year improper payment and unknown payment rate of 3.93 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

SBA anticipates establishing a Tolerable Rate for this program in the near future.

The agency has what is needed with respect to internal controls, human capital and information system
and other infrastructure to reduce Improper Payments and Unknown Payments.

No additional resources for this program were requested.

Additional programmatic information

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2023 - 03/2024


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-1.7

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    SBA provides quarterly training to loan approval staff on the causes of and prevention of improper payments. Training is an ongoing process.
    The corrective action was not fully completed this reporting period
    Not Completed
    Training
    Quarterly training on the causes and prevention of improper payments will continue into FY2025
    FY2025
    Planned

Overpayments

Disaster loans are direct loans made by SBA. Disaster Assistance Loan samples are selected from loan disbursements. A disaster assistance loan may have several disbursements before it is disbursed in full. During the loan review process, SBA reviews the original loan processing and underwriting, any loan modifications, such as increases in the loan amount or additional borrowers, to determine eligibility of the borrower and whether the amount is appropriate. SBA also verifies that the amount of loan is commensurate with the amount of damage. Finally, SBA reviews the actual disbursement to determine that the monies are provided to the right person, in the right amount, and for an eligible use of proceeds.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $24.59 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $24.59 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Financial $24.59 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Training Training

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $17.94 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $17.94 M

Eligibility element/information needed Eligibility amount
Financial $17.94 M

Mitigation strategies taken Mitigation strategies planned
Training Training

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$17.94 M

Unknown Payment Details

Evaluation of corrective actions

The prevalent causes of improper payments stemmed from improper accounting of verified losses on disaster-damaged property, duplication of benefits not adequately addressed, misallocation of loan funds, improper calculation or determination of economic injury eligibility, and closing fees deducted from loans contrary to the Code of Federal Regulations (CFR).

SBA provides quarterly training to loan approval staff on the causes of and prevention of improper payments.

SBA is instituting an updated Standard Operating Procedure (SOP) 50 30, Disaster Assistance Program that streamlines the disaster lending process. Processing automation through the Unified Lending Platform, coupled with the streamlined SOP specifically address the most prevalent causes of improper payments.

In addition to quarterly training for staff, the SBA revised its corrective action processes in FY2022. Corrective actions, which typically include obtaining supporting documentation from the borrower, are completed within 15 days of being informed of the improper payment.

Continuous training, along with other corrective actions, has helped to stabilize improper payments in the Disaster Assistance Program.

Future payment integrity outlook

Disaster Assistance Loans has established a baseline.

The FY 2025 Reduction Targets established for Disaster Assistance is the lesser of the established tolerable rate, or the current reported improper payment rate (i.e., if the FY 2024 improper payment rate is less than the established tolerable rate, the FY 2024 improper payment rate will be the reduction target).

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $1,339.03 M
Current year +1 estimated future improper payments $46.87 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 3.5 %
Current year +1 estimated future improper payment and unknown payment reduction target 3.5 %

The program's current year improper payment and unknown payment rate of 3.62 % has been achieved with a balance of payment integrity risk and controls and represents the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is the tolerable rate.

Management established this tolerable rate range mindful of the extent to which applying further payment controls would undercut the program’s mission or resource management.

The agency has what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce improper payments and unknown payments to the tolerable rate.

No additional resources were requested in the most recent budget submission of the agency to establish and maintain payment integrity.

Additional programmatic information

Disaster Assistance Loans provide low-interest loans to help businesses and homeowners recover from declared disasters. Disaster assistance is available to all businesses located within a declared disaster area, private non-profit organizations, homeowners, and renters affected by declared disasters. Disaster assistance loans can be used to pay for personal or business losses not covered by insurance or funding from other government agencies, as well as for business operating expenses that could have been met had the disaster not occurred. The Disaster Assistance Loan Program is a direct loan program, meaning that SBA approves and makes the loans and there are no intermediary lenders.

The Disaster Assistance Loan program reviews for Improper Payments were conducted to determine whether loans were materially in compliance with SBA guidance, including to determine whether borrowers were eligible for the Disaster Assistance loan, whether the amount approved was correct, whether the loan was made in accordance with existing regulations, Standard Operating Procedures (SOPs) and other internal guidance.
Disaster Assistance Loan samples are selected from loan disbursements. A disaster assistance loan may have several disbursements before it is disbursed in full. During the loan review process, SBA reviews the original loan processing and underwriting, any loan modifications, such as increases in the loan amount or additional borrowers, to determine eligibility of the borrower and whether the amount is appropriate. SBA also verifies that the amount of loan is commensurate with the amount of damage. Finally, SBA reviews the actual disbursement to determine that the monies are provided to the right person, in the right amount, and for an eligible use of proceeds.

Accountability for detecting, preventing, and recovering improper payments

Review standards are established as part of the agency's annual appraisal process. These standards hold managers accountable for meeting applicable reduction targets, preventing improper payments, and promptly detecting and recovering overpayments.

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2024 - 03/2025


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-3.0

Causes

The root cause of improper payments in the Disaster Assistance Loan program was Failure to Access Data/Information and Statutory Requirements of Program Were Not Met. The prevalent causes of improper payments stemmed from fees charged for secured loans contrary to the Code of Federal Regulations (CFR), duplication of benefits not adequately addressed, and improper calculation or determination of economic injury eligibility.

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $125.08 M
Amount of overpayments outside the agency's control $0.0 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $125.08 M

Underpayment root cause Underpayment amount
Amount of underpayments $31.94 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $31.94 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $0.0 M

Prevention

During FY 2025, the Disaster Lending Operations Division (DLOD) utilized the Unified Lending Platform (ULP) to facilitate loan closings for disaster survivors in an effort to streamline the process and reduce administrative burden. It was subsequently identified that DLOD was not authorized under 13 CFR 123.8 to charge certain fees associated with the loan closing process, resulting in a regulatory compliance issue rather than a breakdown in eligibility determination or payment processing controls. This issue represented the root cause of the improper payments identified for the Disaster Assistance Program.

In response, the agency implemented a corrective action in February 2025 that provided disaster survivors the option to either complete the loan closing independently or explicitly authorize the Agency to complete the closing on their behalf. This change ensured compliance with regulatory requirements governing fee authority while maintaining borrower flexibility and operational efficiency. The corrective action directly mitigated the identified root cause by eliminating unauthorized fee activity during the loan closing process.

In addition, the agency initiated updates to the governing Standard Operating Procedure for the Disaster Assistance Loan Program to clarify closing authority, fee requirements, and documentation standards associated with ULP processing. Targeted training and internal feedback were provided to staff to reinforce regulatory requirements and ensure consistent application of the revised closing procedures. These actions were implemented during FY 2025 and are expected to be fully institutionalized through updated procedures and training by the end of FY 2025.

Collectively, these corrective actions address the specific regulatory gap that caused the improper payments, reduce the likelihood of recurrence, and strengthen internal controls without imposing unnecessary additional burden on disaster survivors or staff.
Corrective actions for the Disaster Assistance Program are structured to address the root causes of Improper Payments and Unknown Payments and are proportional to the associated risk. The agency is updating the Standard Operating Procedure governing the Disaster Assistance Loan Program to strengthen internal controls and clarify program requirements. In FY 2025, the Disaster Lending Operations Division (DLOD) began using the Unified Lending Platform (ULP) to streamline loan closings for disaster survivors and reduce administrative burden. During implementation, it was identified that DLOD was not authorized under 13 CFR 123.8 to charge certain fees related to the closing process.

In response, SBA implemented a corrective action in February 2025 allowing disaster survivors to close their loans independently or authorize the agency to complete the closing to ensure regulatory compliance. SBA also provides targeted internal feedback and employee training to reinforce policy expectations and improve documentation accuracy. These actions directly address the identified root cause and strengthen program oversight. Collectively, the updated SOP, enhanced training, and revised closing procedures reduce the likelihood of future Improper Payments and Unknown Payments.

Corrective actions for the Disaster Loan Assistance Program are implemented and prioritized based on the predominant reason for the Improper Payment, ensuring that the agency’s efforts directly address the underlying cause. These actions focus on strengthening reviews and eligibility checks to prevent the recurrence of errors related to duplication of benefits, statutory violations, improper calculation of economic injury eligibility, and the disaster assistance program as a whole. When a potential Improper Payment is identified, SBA contacts the borrower in an attempt to obtain outstanding or clarifying documentation needed to substantiate the original eligibility determination. The agency provides feedback to the lender and applicable SBA employees regarding process and policy errors resulting in the improper payment to ensure consistent understanding and application of program requirements. These corrective actions are adequate to address the root causes of Improper Payments and Unknown Payments and have contributed to improvements in program compliance and payment accuracy. As implementation continues, the actions are expected to further reduce Improper Payments and Unknown Payments within the Disaster Assistance Program.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Training Training
Underpayments Change Process, Training Change Process, Training

Eligibility element/information needed Description of the eligbility element/information
Financial The financial position or status of a beneficiary, recipient, or their family
Receiving Benefits from Other Sources Beneficiary or recipient is receiving benefits from an additional source

Additional information

Reduction target

4.25 %

The agency has internal control, human capital and information system and other infrastructure to reduce improper payments and unknown payment.

In the most recent budget submission, the agency requested to maintain current resources to support workforce capacity and operational activities required to ensure payment integrity of the Disaster loan program during testing, recoupment, and closeout. These resources are intended to support staff responsible for post-award reviews, improper payment identification, recovery efforts, and closeout activities. Despite overall resource constraints in fiscal year 2025, the program prioritized available staffing and funding to sustain payment integrity functions and ensure compliance through the recoupment and closeout phase.

As a means to reduce and/or eliminate the occurrence of improper payments, a Corrective Action Plan has been developed for the program. In addition, managers are held accountable for meeting the program's improper payment rate and unknown payment rate reductions targets. Senior management is responsible for implementing a Quality Control review process. In addition, senior management has established and maintained sufficient and appropriate control environment.

$31.94 M