CORRECTIVE ACTION PLAN — Finding 2025-002 Compliance Finding – Cash Management | Low-Income Home Energy Assistance Program (LIHEAP) (ALN 93.568) Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | Pass-Through Entity: State of Vermont Department for Children and Families | Cognizant Federa...
CORRECTIVE ACTION PLAN — Finding 2025-002 Compliance Finding – Cash Management | Low-Income Home Energy Assistance Program (LIHEAP) (ALN 93.568) Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | Pass-Through Entity: State of Vermont Department for Children and Families | Cognizant Federal Agency: U.S. Department of Health and Human Services | CAP Contact: Joshua Davis, Executive Director, JDavis@sevca.org 1. Summary of Finding Finding 2025-002 identified that SEVCA drew the maximum allowable 50% advance under the LIHEAP award at the onset of the grant period without a documented cash flow forecast or disbursement schedule demonstrating that the amount drawn was limited to actual, immediate program needs. Approximately 30 days after receipt, a significant portion of the advance remained unexpended. This is not consistent with 2 CFR 200.305(b), which requires advances to be limited to the minimum amounts needed and timed to minimize the elapsed time between receipt and disbursement of funds. 2. Management’s Response SEVCA concurs with the finding. No questioned costs were identified. Management is implementing the corrective actions below. 3. Corrective Actions 1. Develop and implement a written Cash Management Procedure requiring that each advance drawdown request be supported by a documented cash flow forecast / disbursement schedule covering the period through the next expected draw date for that award, in accordance with 2 CFR 200.305(b) — Finance Director; 9/1/26. 2. Limit advance drawdown amounts to anticipated disbursements through the next scheduled draw date, rather than defaulting to the maximum allowable advance percentage — Finance Director; 9/1/26. 3. Formalize Finance Director review and sign-off of draw requests, and require independent review and sign-off by the Executive Director prior to submission, to explicitly document verification of the supporting forecast and the next expected draw date, and the amount requested — Finance Director / Executive Director; 9/1/26. 4. Use a single recurring draw worksheet per award documenting cash on hand, anticipated disbursements through the next draw date, and the amount requested, while reconciling the prior draw’s actual disbursements against projections and flagging any idle balances — Finance Director; 9/1/26. 5. Train relevant staff on the updated procedure and 2 CFR 200.305 requirements, and retain completed draw worksheets to support future audit testing — Finance Director / Accounting Staff; 9/1/26, retention ongoing. 4. Anticipated Completion Date 9/1/26. 5. Monitoring The Finance Director will review completed draw worksheets as part of each draw cycle; the Executive Director will independently review and sign off on each draw worksheet prior to submission, and will assess quarterly whether advances are being appropriately sized and timely utilized across federal awards. Draw worksheets, supporting forecasts, and sign-offs will be retained to support future audit testing.