Corrective Action Plans

FINDING 2025-001 (Auditor Assigned Reference Number) Finding Subject: TRIO - Eligibility Contact Persons Responsible for Corrective Action: John Gipson, Lake County Chancellor Contact Phone Number and Email Address: 812-297-3252 and jgipson33@ivytech.edu Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The College will ensure that each affected campus develops and implements a plan that incorporates internal controls to mitigate risk and ensure compliance with applicable requirements. Campus Project Directors will be responsible for maintaining complete and accurate documentation, including required dual signatures. Anticipated Completion Date: June 30, 2026

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University review its SAP policies to ensure they met the minimum requirements and that they are fully implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Historically the Graduate School was responsible for reviewing SAP and notifying Student Financial Services (SFS) if students needed to be warned or suspended. Going forward, SFS will begin reviewing graduate students for SAP to ensure accurate and timely notifications are in place. Additionally, SFS is reviewing the current logic to ensure GPA is accurately reviewed in the baseline SAP process. Student Financial Services 11 Garrison Avenue - Stoke Hall Durham, NH 03824 Name(s) of the contact person(s) responsible for corrective action: Elizabeth Stevens, Director, Student Financial Services, University of New Hampshire Planned completion date for corrective action plan: July 1, 2026

2025-001 - ELIGIBILITY Auditee’s Response and Planned Corrective Action Rockport Housing Authority (RHA) contracted with Newburyport Housing Authority (NHA) to manage the Section 8 program. They will be calculating income, assets and/or medical expenses based on HUD regulation. NHA is staffed with an experienced Section 8 Coordinator. In addition, NHA uses Rent O Meter to provide Rent Reasonableness Reporting that will be entered into PHA Web as a method of recording. Planned Implementation Date of Corrective Action: June 30, 2026 Person Responsible for Corrective Action: Marie Mathas, Executive Director

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT S3800-010: Finding Reference Number 2025-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of tenant income certifications and new tenant move-in files. However, during our testing, we noted four (4) move-in files out of four (4) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. In addition, there was no evidence of approvals of tenant income certifications in the tenant files prior to billing of rental assistance for eleven (11) out of twelve (12) tenant files tested. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy and no billing of rental assistance based on certifications should be billed until the file has been approved by the independent contractor conducting the compliance review.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.556) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future, including maintaining appropriate documentation. Official Responsible – Dawn Duevel, Business Services Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Dawn Duevel, Business Services Director, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

Assistance Listings number and program name: 14.195 Section 8 Project-Based Cluster (Project-Based Rental Assistance (PBRA)) Responsible Entity: Housing Authority of Maricopa County Contact Person(s): Gerald Minott, Executive Director, Housing Authority of Maricopa County. Anticipated completion date: April 12, 2026 Concur: The Housing Authority of Maricopa County (HAMC) has set up automatic build in compliance alert in Yardi Voyager that will adopt HUD software requirement tools while also creating a compliance calendar for the fiscal year which should further assist in the prevention of late inspections and recertifications. Going forward the HAMC Compliance Department will be performing biannual internal monitoring tests of up to (25%) of files per site/property/program. As part of HAMC’s push to implement internal control best practices, HAMC will update its internal control policies on electronic income verification deadlines, inspection frequency, required documentation, correction of income verification steps, and file retention rules to provide better clarity. HAMC will also work with the HAMC HR Department staff to implement a zero-tolerance policy for incomplete files which will be reviewed on a yearly basis.

Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 prompting the Program Director to file, or work with appropriate staff to file the FFATA.

2025-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Client #20 Corrective Action: Section 1 RE: Incorrect Rental Calculation: The incorrect calculation referenced in this finding was due to a typo, which resulted in an incorrect payment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2023-24 audit: 2023-24 Total Deficient Eligibility Records: 2024-25 Total Deficient Eligibility Records: WNCAP expects to see continued improvement in subsequent audits.

Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of noncompliance the college was transitioning to a new financial aid system. The compliance engine of the new system was set up but there was a gap in the compliance which allowed aid for students who were not enrolled to post without warning. The issue was found by the financial aid administrators and corrected as soon as it was discovered. Upon finding the issues, the financial aid administrators reached out to the IT department for more training on the compliance portion of the software and have worked diligently to update the system and put in place processes that will ensure that aid is canceled for students that are not enrolled. The system also has compliance setup to ensure checks and balances are in place to look for students who are eligible to receive aid and will not post aid for students who are not enrolled even if the aid has not been canceled before the official disbursement date.

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-001 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6, 2 H80CS00646-24-01, 1 H8LCS51923-01-00 for 2024 and 2025, 1 H8NCS54043-01- 00 for 2025 - (Significant Deficiency) During our audit, we noted that the Center did not properly determine the sliding fee discount for one eligible patient, based on information provided during the patient registration process. Recommendation We recommend that the Center provide training to all personnel involved in determining patients’ sliding fee discounts. In addition, we recommend that an internal audit of a sample of patient charts be conducted periodically to verify that sliding fee scale discounts or categories are properly and accurately determined based on the information provided by patients. Finally, we recommend that the results of such internal audits be formally documented. Action Taken Management agrees with the finding and will be establishing policies and procedures and conducting training for all personnel involved in determining patients' sliding fee discounts to help ensure the accuracy of the process. Management will also implement an internal audit of a sample of patient charts and will ensure that such audits are properly documented. Effectivity Date: June 30, 2026

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy implement a process to ensure student is being properly awarded based on their SAI and enrollment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Coordinators now have a corrected calculator to use when determining the student’s Pell eligibility based on their SAI. The Financial Aid Manager will also look over the award to ensure proper funding has been put into place. Name(s) of the contact person(s) responsible for corrective action: Rachael Farnell Planned completion date for corrective action plan: 07/01/2025

CORRECTIVE ACTION PLAN March 18, 2026 Housing for Rockdale Elders, Inc. respectfully submits the following corrective action plans for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2025-003 - Eligibility - Material Weakness Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Action Taken: Management agrees with the finding and is in the process of revising internal controls to address this issue.

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-305: Grants to States for Medicaid – Posting of Managed Care Entity Financial Audits. This is the department’s Corrective Action Plan.  Recommendation (2025-305): Grants to States for Medicaid – Posting of Managed Care Entity Financial Audits We recommend the Wisconsin Department of Health Services develop and implement procedures to ensure the results of the periodic audits of managed care organizations are posted to the State’s website in a timely manner. Wisconsin Department of Health Services Planned Corrective Action: DHS will establish a tracking process to post the summary results of the managed care entity financial audits to the State’s website in a timely manner. Anticipated Completion Date: June 30, 2026 Persons responsible for corrective action Grant Cummings, Director Bureau of Rate Setting, Division of Medicaid Services grantr.cummings@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-304: Grants to States for Medicaid – Medical Status Code Errors. This is the department’s Corrective Action Plan.  Recommendation (2025-304): Grants to States for Medicaid – Medical Status Code Errors. We recommend the Wisconsin Department of Health Services ensure the accuracy of the medical status code by: • Implementing and testing the needed updates to CARES to correct the errors in the assigned medical status code; • Completing an assessment of the effect of the identified errors in the medical status code on accounting entries, required federal reporting, and making any necessary corrections; and • Prepare and maintain documentation of its annual review and assessment. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) identified issues with Medical Status codes prior to the beginning of the audit. DMS directed the Enrollment & Eligibility System vendor to identify and implement a system correction. Concurrently, the LAB identified the issue as part of their current year audit fieldwork. The correction was included in the February 2026 system update which is expected to address the concerns underlying this finding. Additionally, DMS will complete an assessment of potential effects on required federal reporting and make any adjustments. Anticipated Completion Date: June 30, 2026 Persons responsible for corrective action: Hannah Stephens, Section Manager Bureau of Fiscal Accountability and Management, Division of Medicaid Services, hannah.stephens@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-301: Grants to States for Medicaid and Children’s Health Insurance Program – Computer Data Matches. This is the department’s Corrective Action Plan.  Recommendation (2025-301): Grants to States for Medicaid and Children’s Health Insurance Program – Computer Data Matches. We recommend the Wisconsin Department of Health Services: • Identify and implement procedures to monitor the timeliness with which data match discrepancies are resolved and perform follow-up with local agencies as needed; and • Continue efforts to assess solutions for resolving state wage information collection agency data match discrepancies in a timely manner to determine if system or policy changes are needed. Wisconsin Department of Health Services Planned Corrective Action: Beginning in February 2026, the Medicaid Eligibility Quality Control Unit will include State Wage Information Collection Agency (SWICA) discrepancies in the monthly report that is available to Income Maintenance (IM) agencies through SharePoint. IM workers are expected to address the discrepancies. The Medicaid Eligibility Quality Control Unit will monitor the agencies to ensure they are completing the SWICA work. Prior to receipt of this finding in the fall of 2025, DHS initiated a project to assess the current state of SWICA discrepancy processing, develop solutions to improve the process, and consider automation options. The Bureau of Eligibility Operations and Training and the Bureau of Eligibility Enrollment and Policy are currently weighing several proposed solutions. If it is determined that changes to CARES are required, the project completion will depend on prioritization and coordination of CARES updates. Anticipated Completion Date: November 2027 Persons responsible for corrective action: Jonelle Brom, Director Bureau of Eligibility Operations and Training, Division of Medicaid Services Jonellem.Brom@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-300: Eligibility for the Children’s Health Insurance Program. This is the department’s Corrective Action Plan.  Recommendation (2025-300): Eligibility for the Children’s Health Insurance Program We recommend the Wisconsin Department of Health Services continue its efforts to monitor for Children’s Health Insurance Program participants who exceed the age requirement to ensure they are identified and removed in a timely manner. Wisconsin Department of Health Services Planned Corrective Action: On August 1, 2025, a CARES Coordinator Notice was sent to Income Maintenance agencies to emphasize the Monthly BC CHIP Report, which provides a list of individuals aging out of the program in the following month. Beginning with this notification, agencies were required to work the cases on the list and notify DHS of completion on or before the 10th of each month. Since August 2025, agencies have followed the directives in the notice and are informing DHS when work is completed on each case. Anticipated Completion Date: August 2025 Persons responsible for corrective action: Jonelle Brom, Director Bureau of Eligibility Operations and Training, Division of Medicaid Services Jonellem.Brom@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-303: WIC Supplemental Nutrition Program for Women, Infants, and Children – Service Organization Controls. This is the department’s Corrective Action Plan.  Recommendation (2025-303): WIC Supplemental Nutrition Program for Women, Infants, and Children – Service Organization Controls. We recommend the Wisconsin Department of Health Services: • Develop and document procedures to complete an annual assessment of the controls in place by each contractor that provides support and security for an IT system used in administering the WIC Special Supplemental Nutrition Program for Women, Infants, and Children program, including the support provider, the cloud provider, and the EBT provider; • Obtain annually available service organization controls audit reports and perform an annual review that includes an assessment of the identified internal control deficiencies and a determination of whether the relevant complementary user entity controls are implemented; and • Prepare and maintain documentation of its annual review and assessment. Wisconsin Department of Health Services Planned Corrective Action: In partnership with DHS’s Information Security Section (ISS), the WIC Program will develop and document procedures to complete an annual assessment of security controls. The WIC Program will annually request SOC reports from all vendors. ISS will review SOC reports identifying deficiencies and risks and ensuring the user entity controls are addressed. DHS will then prepare and maintain documentation of its annual SOC reviews and assessments. Anticipated Completion Date: June 1, 2026 Persons responsible for corrective action: Kari Malone, Section Manager WIC and Nutrition Section, Division of Public Health kari.malone@dhs.wisconsin.gov

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child and Adult Care Food Program – Assistance Listing No. 10.558 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SC CACFP staff has reviewed USDA CACFP Federal Regulation 7 CFR 226.6(b)(3) and 2 CFR 200.303 regarding notifying new and renewing institutions applying of the approval or disapproval by the State agency. Additional training will be provided to staff processing CACFP applications. State agency staff reviewing applications for approval will monitor the SC CACFP Online Application Dashboard and emails for pending final approvals for CACFP Applications and will complete the approval or denial within 30 days of the pending final approval date. Anticipated Completion Date: March 31, 2026 Names of the contact persons responsible for corrective action: • Greta F. Avery, CACFP Supervisor at (803) 898-7576 • Dyeretta M. Fashion, CACFP Supervisor at (803) 898-0945 • Mary A. Young, CACFP Manager at (803) 898-0958

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SCDSS will collaborate closely with SCDHHS to ensure eligibility policies and procedures for the Refugee Medical Assistance (RMA) program clearly and accurately define program eligibility requirements. SCDSS will also ensure that staff responsible for processing RMA applications receive appropriate training to apply these policies consistently and correctly. To support ongoing compliance, SCDSS will implement a quarterly monitoring plan designed to identify any individuals incorrectly categorized under RMA. SCDSS will maintain continuous communication and follow-up with SCDHHS to verify timely implementation of these corrective actions and to address any issues that arise. Anticipated Completion Date: July 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303 • Brittney White, State Refugee Health Coordinator at 803-898-7545

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Adoption Assistance – Assistance Listing No. 93.659 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: As of July 1, 2024, all children are considered applicable no matter their age. Due to this change, there is only one eligibility determination form to be completed. The department has archived the non-applicable form, and it is no longer accessible to the Regional Staff. Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Melissa S. Lowe at 803-898-7194

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Adoption Assistance – Assistance Listing No. 93.659 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The program will work with IT to establish a notification method sent to State Office Adoptions when a foster care maintenance payment and an adoption subsidy payment are being paid for the benefit of a child at the same time. This will allow State Office Adoptions to be able to research whether the adoption subsidy payment needs to be terminated, adjusted, or if the adoptive parent must submit proof of support for the child. Anticipated Completion Date: December 31, 2026 Names of the contact persons responsible for corrective action: • Melissa S. Lowe at 803-898-7194

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS management concurs with the audit finding. Corrective Action: Regarding the Provider Enrollment Revalidation finding - One provider whose last enrollment validation date was 5/10/2014. The revalidation date for this provider would have been due by 5/10/2019 which would have been before the start of the Public Health Emergency (PHE). The current Provider Enrollment and Support Functions Team Director was not with SCDHHS at the time of the missed revalidation and we are unable to attest to reasons this provider did not complete revalidation, as required. Anticipated Completion Date: Our post-PHE revalidation restart began in July 2024 and will conclude by the required completion date of February 28, 2027. Once SCDHHS completes our current revalidation schedule, we will resume normal revalidation cadence. Contact persons responsible for corrective action: • Dawn Hunt at (803) 898-1843 • Nick Constantino at (803) 898-2561

Reference Number: 2025-021, 2019-010 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2405VT5MAP (10/1/2023 – 9/30/2024) 2505VT5MAP (10/1/2024 – 9/30/2025) Compliance Requirement: Special Tests and Provisions - Provider Health and Safety Standards Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review procedures and controls and complete implementation of its corrective action plan from a prior audit to ensure that documentation is maintained in accordance with program requirements and that all providers are compliant with required health and safety standards. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: All Letters of Good Standing as well as a Standard Operating Procedure to ensure continuation were implemented in April of 2022. Prior to April the process was manual and via telephone or email with the Tax Department. All providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to get a written notification from the Tax Commissioner. As of April 2022, all tax standing reviews are validated within the Vermont Department of Taxes MyVTax portal. A confirmation of good standing is uploaded to the case within the Provider Management Module (PMM) and documented within the system. If verification cannot occur through the MyVTax portal, a Lexis Nexis report is run to validate if any liens or judgments result, the report is attached within PMM, and the system is documented. If verification of good standing does not result from either method, the application is returned to the provider to produce written confirmation of good standing from the Vermont Department of Taxes. The document is uploaded into PMM at this point. Although the Agency has implemented its corrective action plan from a prior year audit, cases will still be identified under this CAP until the provider is due for their 5-year revalidation and successfully revalidates with VT Medicaid. The additional provider identified during the selection of sixty providers for testing, for which a tax standing verification was not performed during revalidation, was the result of an isolated oversight attributable to human error. The Agency has determined that this instance does not reflect a systemic deficiency in the tax verification process. A tax standing verification for the identified provider was conducted post-audit in September 2025 and confirmed the provider was in Good Standing. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Deidra Jarvis, Provider Member Relations Manager, diedra.jarvis@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

Reference Number: 2025-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Foster Care – Title IV-E Assistance Listing Number: 93.658 Award Number and Year: 2401VTFOST (10/1/2023 – 9/30/2025) 2501VTFOST (10/1/2024 – 9/30/2026) Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it correctly identifies the eligible federal program for all cases coded in CDDIS. We further recommend that children on whose behalf payments are charged to Foster Care are eligible for benefits under the program. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency will work with the IT systems of both the Family Services and Child Development Divisions to ensure that accurate eligibility information is shared between the systems. This will include: 1. What program each child is eligible for, adoption or foster care 2. The accurate start and end dates of eligibility 3. Any changes to eligibility during the life of a case The staff from Family Services will ensure that all Title IV-E eligibility information is shared with IT as they create the processes to share that information with the Child Development Division. The staff at the Child Development Division will work with their IT vendor to ensure all updates are completed and tested to ensure that Title IV-E funds are being claimed appropriately. Scheduled Completion Date of Corrective Action Plan: The underlying work to clarify the eligibility information needed has already begun and the process of updating the IT systems on both the FSD and CDD sides will be completed by April 1, 2026. Contacts for Corrective Action Plan: Heather McLain, Revenue Enhancement Director, Family Services, heather.mclain@vermont.gov Brenda Hallock, Revenue Team Lead, Family Services, brenda.hallock@vermont.gov Karolyn Long, Operations Director, Child Development Division, karolyn.long@vermont.gov Ed Dwinell, Financial Director, DCF Business Office, ed.dwinell@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

Reference Number: 2025-019 Prior Year Finding: 2024-020 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2401VTCCDD (10/1/2023 – 9/30/2026) 2501VTCCDD (10/1/2024 – 9/30/2027) Compliance Requirement: Special Tests and Provisions – Health and Safety Requirements Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance training monitoring procedures and controls to ensure that all child care providers complete required health and safety training. The Agency should update its training content to include all required elements and ensure that provider corrective action plans and documentation are properly maintained. Site visit documentation should clearly indicate the results of training requirement monitoring. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: DCF-CDD continues their rule revision process and now has the added support of a project manager and legal counsel. The revision process has been rigorous, and the rules have undergone several drafts. The public has had another opportunity to provide feedback on the latest draft prior to the formal promulgation process. Additionally, CDD received technical assistance from our federal partners to ensure our rule revisions met all CCDF requirements and will continue to refer to this document as we move the rules towards promulgation. The proposed rules will address the findings documented in this audit related to the federal requirement that pre-service orientation includes the required eleven (11) healthy and safety topics which staff will be required to complete, “before being left alone with children, counted in staff to child ratios, or within one (1) month of starting employment, whichever comes first.” DCF-CDD submitted an RFP for a new pre-service orientation training to include all the required health and safety topics that must be covered within the first month of employment. CDD will continue to work with the apparent successful bidder to ensure these modules are available to the field in 2026. DCF-CDD licensing unit will review the results of the single audit with licensing staff and our partners at Northern Lights at CCV (NL). CDD will begin a shift in our site visit preparation process that includes NL providing the division with a complete list of staff who have and who have not completed the required number of annual training hours. CDD licensing will document deficiencies in site visit reports and will require a plan from the providers to come into compliance. Scheduled Completion Date of Corrective Action Plan: DCF-CDD anticipates the licensing rules will be submitted to ICAR on February 20, 2026. This date may need to shift dependent on legal counsel’s final review of the rules and the weeks needed to prepare the documents required at this stage in the promulgation. CDD will be provided with a promulgation timeline which we aim to have completed before the end of 2026. DCF-CDD will seek outside contractual support to develop guidance manuals and training for the field on the rule changes, which includes shifts in required pre-service orientation topics. DCF-CDD pre-service orientation modules are scheduled to be completed within six (6)-nine (9) months from when the contract has been signed between the SOV and the apparent successful bidder. DCF-CDD will implement the site visit preparation practice shift by April-May 2026. This work requires NL staff to shift job responsibilities to accommodate the ongoing training review of the staff for all providers. By January 26, 2026, CDD director of child care licensing will meet with the licensing supervisors to review the results of this audit, review the CAP, and establish a plan for supervisory oversight at it relates to licensors documenting training deficiencies when conducting site visits. By January 27, 2026, CDD director of child care licensing will meet with the licensing unit to review the results of this audit, review the CAP, discuss the shift in site visit preparation practice as we partner with NL who will be reviewing compliance with annual training hours, and discuss the expectations around how deficiencies must be documented in annual site visit reports. Contacts for Corrective Action Plan: Beth Maurer, Director of Child Care Licensing, elizabeth.maurer@vermont.gov Kelly Lyford, Licensing Supervisor, kelly.lyford@vermont.gov Janet McLaughlin, CDD Deputy Commissioner, janet.mclaughlin@vermont.gov Dawn Rouse, Director of Statewide Systems, dawn.rouse@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov