Implement written policies and procedures that result in : (1) charging fringe benefits and training costs based on actual, allocated costs to federal grants; (2) using of actual, allocated direct costs in its calculations of indirect cost and recording these expenditures in its financial management system; (3) determining drawdowns using actual cost data from its financial management system, (4) adequately tracking its expenditures against its approved budget and ensuring that SRF’s federal financial reports are accurately completed using official financial accounting records containing all actual grant expenditures incurred for the reporting period.