Miami Beach Cultural Arts Council Audit (Period 10-1-17 to 9-30-18) 5-30-19MIAMIBEACH
INTERNAL AUDIT REPORT
City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov
Office of Internal Audit
Tel: 305-673-7020
TO: Jimmy L. Morales, City Manager
VIA: Mark Coolidge, Interim Internal Au , or MCA
FROM: Coral Vivolo, Auditor %✓
DATE: May 30, 2019
AUDIT: Miami Beach Cultural Arts Council Audit
PERIOD: October 1, 2017 to September 30, 2018
We have completed the regularly scheduled audit of the Miami Beach Cultural Arts Council
(CAC) as required by Section 2-64 of the City Code, for the period of October 1, 2017 through
September 30, 2018. This audit was performed to determine whether the CAC complied with
the provisions set forth in Chapter 2, Article III, Division 6 of the City Code entitled "Cultural Arts
Council," and to determine whether grants were awarded in accordance with the Program
Guidelines and Eligibility Requirements. During the audit period, $850,000 in grant monies
were awarded to 48 applicants as approved by Resolution No. 2017-29966.
INTRODUCTION
The City Commission passed Ordinance No. 97-3075 on March 5, 1997 thereby creating the
CAC. The CAC consists of eleven (11) members appointed at large by a majority vote of the
Mayor and -City Commission. It was created to develop, coordinate, and promote the performing
and visual arts in the City for the enjoyment, education, cultural enrichment, and benefit of both
residents and visitors. Since the program's inception, the City has awarded approximately $18
million in cultural grants.
Staff from Cultural Affairs, a unit of the City's Tourism, Culture and Economic Development
Department (renamed Tourism and Culture Department in January 2019 through the passage of
City Resolution No. 2019-30688), in conjunction with the CAC have the primary responsibility of
reviewing applications received for the Cultural Arts Grant Program on an annual basis,
ensuring that applicants meet the eligibility criteria, and providing award recommendations to
City Administration.
To qualify for the grant program, applicants must be non-profit, 501(c)(3) cultural organizations
or cultural departments within an institution of higher learning (college or university) with tax-
exempt status under other subsections of 501(c)(3), wishing to present or produce cultural and
artistic events in the City of Miami Beach. In addition, they must complete the required
application and provide the necessary documentation (Internal Revenue Service Form 990,
organizational chart, etc.) by the established grant program deadlines.
The grant program currently offers two (2) categories, Anchors/Junior Anchors and Cultural
Presenters. Within the Cultural Presenters category, there are six (6) different sub -categories
including, Film, Visual Arts, Theater, Multi -Disciplinary, Dance and Music. Award amounts for
Anchors/Junior range from $10,000 to $35,000 depending on the annual organizational budget,
while for Cultural Presenters, as per the Program Guidelines, there is no funding cap. However,
We are committed to providing excellent public service and safely to all who live, work, and play in our vibrant, tropical, historic community.
Internal Audit Report
Miami Beach Cultural Arts Council Audit
May 30, 2019
it was noted that Cultural Presenters grantees received awards ranging
g g from $7,000 to $25,000
during the 2017/18 fiscal year. The actual grant amounts awarded are determined by the CAC
based on the projects being presented and the grantees' application s g pp core.
CAC program grants are funded via Resort Tax revenues. In fiscal
year 2014/15, the city
Commission accepted the recommendations of the Finance and Citywide
yw de Projects Committee to
modify the split of the Resort Tax Funds to allocate ten percent(10%)toCAC . p funding for arts (i.e.
} During the audit period, October 1, 2017 through September
$1,327,000 wasg p 30, 2018, a total of
appropriated to the CAC. Of these monies, $850,000 was awarded to 48
applicants during the 2017/18 fiscal year through the CityCommission's s
of Resolution No. 2017-29966.
subsequent ratification
OVERALL OPINION
Internal Audit noted a significant improvement during this ear's a
Operations A g Y audit as the Grants and
O
p Administrator, hired in November 2017, has been given more time to c
from the g correct the
deficiencies arising e position being vacant for a period eight (8) months. Based on the
result of our audit, the findings below were noted and are in need of corrective
action.
1. Documentation provided by grantees was not in compliance
p ce with the eligibility
requirements of the program guidelines and application instructions.
2. Grant awards were not timely disbursed.
3. Lack of supporting documentation resulted in a reduction of gran
t t awards.
4. Accrual journal entry for unpaid CAC grant awards was not r ' recorded in the City s
Financials.
5. Required annual public hearing was not held.
SCOPE, OBJECTIVES, AND METHODOLOGY
The scope of the audit was to evaluate whether the CAC complied with
Chapter 2 p the provisions set forth
in Cha
p , Article III, Division 6 of the City Code entitled "Cultural Arts Council,"
determine whether rants were and
g awarded in accordance with the Program Guidelines and
Eligibility Requirements. The audit covered the period October 1 2017 through September 30,
2018, and selected transactions prior and subsequent to this period.
focused on theq p d In general, the audit
following objectives:
• To determine whether the Cultural Arts Council complied with the rove
Chapter 2 Article the City Code titled "Cultural Arts
p provisions set forth in
Cha
p c e III, Division 6, Section 2-55 of
Council."
• To determine whether the applicants selected met the eligibility re
rant category for which g Y requirements of the
g g ry ich they applied.
• To determine whether the CAC properly reimbursed grantees an amount mount within the
maximum allowed fo
r their organization type (for Anchors only), and not to exceed the
City Commission approved total.
• To determine whether the grantees complied with the Final r Report
forth in the Grant Agreement.
p requirements set
• To ensure that awarded grant payments were properly recorded in the '
System.
p Y e Citys Financial
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May 30, 2019
• To determine whether deficiencies noted in the prior audit have been corrected.
We conducted this performance audit in accordance with the Standard Operating Procedures of
the City of Miami Beach Office of Internal Audit as well as internal audit best practices. Those
require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings and conclusions based
on our audit objectives.
The audit methodology included the following:
• Reviewed applicable provisions within the City Charter and Code of Ordinances, and
City policies and procedures;
• Interviewed and made inquiries of staff in order to gain an understanding of the internal
controls (relative to the award of CAC grants), assess control risk, and plan audit
procedures;
• Performed substantive testing consistent with the audit objectives, including but not
limited to examination, on a sample basis, of applicable transactions and records;
• Drew conclusions based on the results of testing, made corresponding
recommendations, and obtained auditee responses and corrective action plans; and,
• Performed other audit procedures as deemed necessary.
FINDINGS, RECOMMENDATIONS AND MANAGEMENT RESPONSES
1. Finding: Documentation Provided by Grantees was not in Compliance with the Eligibility
Requirements of the Program Guidelines and Application Instructions
The Cultural Affairs staff is responsible for ensuring that grantees meet the eligibility
requirements of the Cultural Arts Grant Program set forth in the Program Guidelines and
Application Instructions and comply with the terms of the executed Grant Agreement. As
per the City's Cultural Affairs Grant Program Guidelines and Application Instructions -
Eligibility Requirements, only non-profit organizations with a 501(c)(3) tax exempt status,
or cultural departments within an institution of higher learning (college or university) with
tax-exempt status under other subsections of 501(c)(3), are eligible to apply. As part of
the application process, applicants must meet all requirements and deadlines and
submit/comply with the following:
a) Organization's 501(c)(3) tax-exempt status letter dated within the past two (2)
years.
b) Most recent IRS Form 990 (Return of Organization Exempt from Income Tax),
signed.
c) Organizational Chart (for Anchors only).
d) Current board membership (with contact information) and staff lists with brief
biographies.
e) Sample surveys obtained.
f) All itemized in -kind contributions. In -kind contributions may not exceed 25% of
the total organizational budget and total cash project budget.
g) Minimum $1 to $1 funding match, through cash, in -kind, or a combination of both
(not applicable to Anchors).
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May 30, 2019
Applications are submitted on-line, through the City's Cultural Affairs Program On -Line
Application Web Site, at which time applicants must attach the required documentation
(i.e. signed IRS Form 990, current board membership, etc.), and complete their financial
information (i.e. organizational budget, itemized project and grant award budget, in -kind
contributions, etc.).
Internal Audit reviewed eighteen (18) of the 48 CAC grantees who were awarded
$319,237 (or 37.50%) of the $850,000 total during the 2017/18 fiscal year, to determine
their compliance with the grant program eligibility requirements. Based on our review,
the following deficiencies were noted:
• For eighteen (18) grantees, Internal Audit was unable to determine whether the
grant applications and/or the application corrections were submitted timely. CAC
upgraded their application software and no longer had access to obtain
applications from the 2017/18 fiscal year.
• Nine (9) grantees provided the required 501(c)(3) tax exempt status letter within
the required two-year period. However, said forms were dated after the
application submission due date.
• Eleven (11) grantees provided the required IRS Form 990. However, said forms
were signed after the application submission deadline.
• One (1) grantee provided the required IRS "Form 990;" however, said form was
not signed as required.
• Three (3) grantees did not provide the required biographies (bios). One (1)
grantee provided a bio for only one (1) person, while another grantee only
provided bios for two (2) people.
• For two (2) grantees the in -kind contribution was greater than the 25% maximum.
For one (1) grantee, the contribution was 26.18% of the Total Cash Project
Budget while for the other; it was 28.22%.
These exceptions occurred due to personnel changes. The application process for fiscal
year 2017/18 started prior to the hiring of the current Grants and Operations
Administrator. Contributing further to these deficiencies, a new grants system was
implemented in January 2018 and the Cultural Affairs staff no longer had access to
retrieve documentation submitted by the grantees through the previous system.
Recommendation(s):
Although, for fiscal year 2018/19, obtaining the documentation should not be an issue, it
is recommended that going forward, Cultural Affairs staff consult with the City's
Information Technology Department (I.T.) to ensure that back-ups of all documentation
submitted by the grantees through the on-line grant system are maintained.
Management's Response (Cultural Affairs):
In fiscal year 2019/20, Cultural Affairs initiated aPre-Application phase, which requires
all applicants to submit a 501(c)(3) letter of nonprofit determination dated within the past
two years, most recent IRS Form 990s, current board membership with contact
information, staff list with brief biographies, and an organizational chart. For Pre -
Applicants, who do not have the required documentation, they are unable to move their
application submission forward without required documents. The most recent grant
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application also includes a new budget spreadsheet that requires the inclusion of every
in -kind contribution name/amount, and the spreadsheet computes the in -kind
contribution percentage for each applicant automatically (allowing staff to easily identify
which applicants exceed the 25% in -kind threshold). If the in -kind amount exceeds 25%,
the applicant will not be able to submit a full grant application. In addition to the Office of
Internal Audit's recommendation, the Cultural Affairs staff has expanded its hard copy
filing system, printing all applications and attachments as a means of providing sufficient
back-up to the grants software, should a technical error occur in the future. The Division
will contact I.T. about the most effective ways the City can provide digital backup. We
feel that this will rectify all issues described above.
Implementation Date:
The improvements to the hard copy filing system began in January 2018. The addition
of the Pre -Application grant period and updated spreadsheet were initiated in the
January 2019 application. The Division will contact I.T. about the most effective ways
the City can provide digital backup by the end of May 2019.
2. Finding: Grant Awards were Not Timely Disbursed
As per the City's Cultural Affairs Program Guidelines and Application Instructions, the
CAC has established maximum grant award amounts per grant category (i.e. Anchors
and Cultural Presenters) as follows:
1. Junior Anchors and Anchors: major preeminent and smaller art institutions
physically based in the City, whose primary mission is year-round artistic and
cultural programming that contributes significantly to the cultural life of the City.
a). $25,000 for annual organizational budgets below $750,000
b) $30,000 for annual organizational budgets between $750,000 and $3.5
million
c) $35,000 for annual organizational budgets at or above $3.5 million
2. Cultural Presenters: organizations whose primary mission is to produce and
present cultural and artistic productions. As per the Program Guidelines for this
category, there is no funding cap; however, it was noted that grantees received
awards ranging from $7,000 to $25,000.
As per City Resolution No. 2017-29966, a total of $850,000 was awarded to 48 grant
applicants. Awards are to be disbursed in two (2) payments as follows:
• First half payment (50% of the award) issued upon receipt of grantees signed
and completed contracts.
• Second half payment (additional 50% of the award) issued upon receipt and
approval of the Final Report, and required supporting documentation (i.e.
invoices, cancelled checks). Final Reports are to be submitted by the grantee no
later than November 15tn
Although 48 applicants received grant awards, four (4) did not return a signed grant
agreement and were ineligible to receive grant monies. Testing was performed on the 44
remaining grantees to determine whether the reimbursement amounts were within the
maximum allowed per grant category and did not exceed the total approved by the City
Commission upon which the following deficiencies were noted:
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• For one (1) grantee (an Anchor), Internal Audit was unable to determine whether
the grantee was awarded an amount within the limits of the organization as the
Grant Application was not available for review as no physical copy of the
application was maintained, and Cultural Affairs staff no longer had access to the
system to retrieve said application.
• One (1) grantee was incorrectly reimbursed $25 more than the approved grant
amount.
• As of March 2019, thirteen (13) grantees had not been issued the second half
payments totaling $132,352 (or 29%) as additional documentation needed to
support grant expenditures had not been provided by the grantee.
• For two (2) grantees funding for the 2017/18 fiscal year has not been issued as
follows:
i. One (1) grantee was engaged in a legal dispute; therefore, per
recommendation of the City Attorneys Office, their grant award was put
on hold and their grant application file is currently being reviewed. Fund
issuance for this grantee is currently awaiting legal determination.
ii. One (1) grantee did not receive funding due to an oversight. As of March
11, 2019, a request has been approved to issue grant funds to the
grantee for the 2017/18 fiscal year.
• One (1) grantee did not receive the second half payment as the Final Report was
never submitted to the City as required in the Grant Application Guidelines.
It was noted that these exceptions occurred due to personnel and grant system
changes.
Recommendation(s):
Cultural Affairs staff should ensure that the Final Reports and/or any additional
documentation requested from the grantees are timely reviewed and approved. Any
additional supporting documentation requested from the grantee should have a specific
submission deadline. This will help ensure that the second -half payment would be
remitted and recorded within the same fiscal year, or by December 31 It, and that all prior
year awards are properly closed out before upcoming fiscal year awards.
Management's Response (Cultural Affairs):
As of May 16, 2019, Cultural Affairs has closed out FY (fiscal year) 15/16 and submitted
98.58% of all payments due to grantees for FY 16/17. In preparation for FY 17/18, and in
order to further mitigate future delays in payments, the Division initiated a Contract
Submission Deadline of March 15th and has improved its period by working closely with
the City Attorneys Office, Mayor's Office, and Clerk's Office by streamlining its Contract
Execution Pipeline. Additionally, the Division created a streamlined Final Report, which
require Grantees to submit their invoices/payment proofs with a detailed cover sheet,
expediting the reviews/close-outs of Final Reports. The Division works to further
improve the turnaround time of second payments, which require the submission of an
approved final report, by requiring grantees to submit additional requested and/or
missing materials within a two -week timeframe. If missing/additional materials are not
substantiated within the allotted timeframe, the grant is closed, and payment is made
only on expenses substantiated.
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The Division will deduct $25 from the grantee who was overpaid during a multi -year
financial review of their grant files, dating as far back as FY14/15; the deduction will
occur during the second payment of FY18/19.
Implementation Date:
The Cultural Affairs staff began implementing the aforementioned adjustments to the
grants pipeline in FY 17/18. Beginning on May 31, 2019, the Cultural Affairs staff will
release a FY 17/18 Final Report Form, and the submission deadline will be October 15,
2019 (30-days earlier than previous years); the intention of an earlier date is to close-out
all Final Reports by December 31 st (an Internal Audit recommendation). As of May 20,
2019, staff has closed -out 100% of pending FY 15/16 payments and 98.58% of FY 16/17
payments (one grantee is pending Final Payment due to a legal dispute with the City that
was recently lifted).
3. Finding: Lack of Supporting Documentation Resulted in a Reduction of Grant Awards
Article II of the City's Cultural Affairs Program Grant Agreement, titled "General
Conditions," states that in order for the grantee to demonstrate that the grant has fulfilled
its purpose, the grantee must provide the Cultural Affairs Program Manager with a
written Final Report, which shall document the grantee's satisfaction of all requirements
(i.e. copies of all receipts, invoices, cancelled checks and proof of expenditures of grant
monies.) The Final Report must be received by the Cultural Affairs Program Manager no
later than November 15. Said reports, and the supporting documents are reviewed and
signed off by the Cultural Affairs staff (i.e. Grants and Operations Administrator, Program
Manager and the Senior Administrative Manager) prior to issuing payment to help
ensure compliance with all the grant requirements before monies are disbursed.
Eighteen (18) grantees' Final Reports were tested to determine compliance with the
requirements set forth in the Grant Agreement and that reviewed grant expenses were
allowable and accurately paid. Based on our examination of the Final Reports, invoices,
and payment support provided by the grantees, the following deficiencies were noted:
• One (1) grantee did not provide the necessary documentation (invoices/receipts,
cancelled checks, etc.) to account for the total grant awarded. In some cases, the
documentation provided was for unallowable expenses. As a result, Cultural
Affairs staff reduced the second half payment to the grantee; however, an
additional $90 should have been decreased and is due to the City.
• One (1) grantee did not provide documentation (i.e. invoices/receipts, cancelled
checks, etc.) to account for the total allocated to the budget category. As a result,
Internal Audit reduced the budget category and $450 is due to the City.
It was noted that these deficiencies were due to human error and supervisory oversight.
In addition, as part of our follow-up to determine whether the CAC had corrected the
deficiencies identified during last year's audit regarding nine (9) grantees which did not
provide the required documentation to satisfy disbursement of the grant monies
awarded, it was noted that additional documentation to substantiate grant expenditures
was received and reviewed by CAC for six (6) of the nine (9) grantees. However, for the
additional three (3) grantees no further action was taken; as a result, $10,057 is still due
to the City.
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Recommendation(s�
As a result of the disallowed expenditures, it is recommended that the Cultural Affairs
unit collect any monies due, unless additional support (i.e. invoices, cancelled checks,
etc.) is submitted to satisfy requirements of the Final Report. Furthermore, the $10,057
in disallowed 2016/17 fiscal year reimbursements, should be immediately addressed.
Management's Response (Cultural Affairs):
Cultural Affairs will contact the grantees who had unsubstantiated payments in FY 16/17
& FY 17/18 and will require them to either return the funds, substantiate their
reimbursables, or will have deductions in their future grant payments. Beginning with
Final Report submission for fiscal year 2017/18, detailed Final Report cover sheets for
grantees' expenditures were created and all grantees were required to complete and
submit with Final Reports. This addition has helped correct the lack of substantiated
documentation presented in FY 15/16 Final Reports. A drastic reduction in disallowable
expenses from FY 16/17 to FY 17/18 is noted as follows:
1. Previous Audit FY 15/16 Disallowable Expenses: $61,478.86 (or 23.43% of the
sample) of unsubstantiated expenditures paid by the City. To date, of the
$61,478.86 of FY 15/16 unsubstantiated expenditures, the City was able to
substantiate $51,421.86 (or 83.64%) post-FY 16/17 Audit.
2. Current Audit: FY 16/17 Disallowable Expenses: $540 (or 0.17% of the sample)
of unsubstantiated expenditures paid by City.
Implementation Date:
Staff will contact the grantees by May 31, 2019, detailing the insufficiencies and request
the needed documentation or repayments from them. Grantees will be given two (2)
weeks to provide substantiated reimbursables or funds will be withheld from future
payment to grantees or grantee will be ineligible to apply for future grants.
4. Findin : Accrual Journal Entry for Unpaid CAC Grant Awards was not Recorded in the
City's Financials
The Governmental Accounting Standards Board (GASB), which is recognized as the
official source of generally accepted accounting principles (GAAP) for state and local
governments, establishes modified accrual accounting standards. A governmental
entity is focused on current -year obligations, and the modified accrual basis focuses
mainly on short-term financial assets and liabilities. Using the modified accrual method,
an accountant adjusts for obligations that are incurred during an accounting period for
which no payments have been made. The accruals must be added via adjusting journal
entries, so that the financial statements report these amounts.
It was noted that at the end of fiscal year 2017/18 (i.e. 09/30/18), $473,330 of the total
$850,000 grants awarded, had not yet been disbursed to grantees. However, after an
account inquiry and confirmation from the City's Finance Department, it was determined
that the required journal entry to record the liability accrual for the unpaid grant monies
at the September 30, 2018 year-end was not done. As a result, the reported
expenditures were understated, and they will be overstated as of the September 30,
2019 year-end. However, it was confirmed that the rollover for said period was
requested by Cultural Affairs staff and completed by the Office of Budget and
Performance Improvement.
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This exception occurred because the Tourism and Culture Department was unaware of
the need to complete this journal entry. During the 2016/17 fiscal year audit (issued
01/28/19), the department was made aware, and the issue was discussed with the
Finance Department; however, the closing of FY 17/18 (i.e. 09/30/18) had already taken
place.
Recommendation(s):
Cultural Affairs staff should ensure that
accurately and timely completed each year.
the corresponding accrual journal entry is
Management's Response (Cultural Affairs
As stated by the aforementioned Internal Audit finding, during the fiscal year 2016/17
audit, staff was not made aware of the need to complete a journal entry when discussing
the FY 16/17 Internal Audit with the Office of Budget and Performance Improvement.
During meetings, regarding the findings of FY 16/17 Internal Audit, staff responded that
a rollover request, along with a journal entry to record the accrual, would be done
moving forward. However, the notification journal entry was post the closing of FY 17/18.
Accordingly, staff is initiating this correction for the FY 18/19 year.
Implementation Date:
Year-end closing of FY 18/19.
5. Findin : City Code Required Annual Public Hearing was not Held
In accordance with the provisions set forth in Chapter 2, Article III, Division 6, Section 2-
59 (b) of the City Code, the council shall hold at least one public hearing annually,
pursuant to public notice, specifying the date, place of the hearing and the subjects to be
considered, specifically for the purpose of making the council's work known and
investigating and assessing the needs and development of the arts in the City.
In order to determine whether at least one public hearing was held by the CAC during
fiscal year 2017/18, the schedule of meetings and the minutes for all meetings held
during the year were reviewed. In doing so, it was noted that a public hearing was not
held as required by Section 2-59 (b) of the City Code.
As part of the transition, new employees were unaware of such requirement.
Recommendation(s):
The City's Cultural Affairs unit should ensure that in the coming year (October 1, 2018
through September 30, 2019), at least one public hearing is held as required.
Management's Response (Cultural Affairs)'
Cultural Affairs staff has scheduled a CAC Public Hearing during the Cultural Arts
Council meeting on Thursday, July 11, 2019 at 9:00 a.m. Moving forward, it will be
planned to be held annually at the July CAC meeting.
Implementation Date:
Thursday, July 11, 2019
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Internal Audit Report
Miami Beach Cultural Arts Council Audit
May 30, 2019
EXIT CONFERENCE
An exit conference was held on May 28, 2019 in the Office of Internal Audit and OBPI's shared
conference room. Participants included Tourism and Culture Department Assistant Director
Heather Shaw, Administrative Services Manager Luis Wong, and Operations Administrator
Catherine Houlihan, Interim Internal Auditor Mark Coolidge and Auditor Coral Vivolo. Audit
findings and recommendations were discussed, as were management responses, which are
included herein. All were in agreement with the contents of this audit report.
F:\OBPI\$AUD\INTERNAL AUDIT FILES\DOC18-19\REPORTS - FINAL\CAC Report FY 2018.doc
cc: Kathie G. Brooks, Assistant City Manager
John Woodruff, Finance Director
Marcia Monserrat, Chief of Staff
Matt Kenny, Tourism and Culture Department Director
Heather Shaw, Tourism and Culture Department Assistant Director
Brandi Reddick, Cultural Affairs Program Manager
Luis Wong, Administrative Services Manager
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