Ensure Healing Action establishes and implements grant financial management policies and procedures to help ensure adequate administration of federal grant funds and that all relevant personnel are aware of these policies and procedures. In particular, these policies should cover, at a minimum: (1) improving internal controls over its debit card access; (2) complying with DOJ Grants Financial Guide consultant requirements, including prior approval and justification for exceeding the established daily or hourly consultant rate and adequate time and effort reports as well as ensuring its staff understand and adhere to the policies and procedures; (3) allocating costs properly to awards; (4) recording and tracking all matching cost transactions in its accounting system; (5) ensuring drawdowns are based on actual or planned expenditures within the next 10 days and are reviewed and approved by management, as well as maintaining supporting documentation for future auditing purposes; and (6) preparing and submitting accurate Federal Financial Reports (FFR). In addition, the financial policies and procedures should ensure contracted accounting activities comply with the DOJ Grants Financial Guide requirements and the terms and conditions of the grants.