Corrective Action Plans

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Vermont Agency of Digital Services (ADS) meets the biennial ADP system security review requirement on behalf of Vermont Agency of Human Services (AHS) via an IRS Security Audit (cadency of every three years) and by contracting with 3rd party security risk assessment firms like JANUS Associates. Bot...
Vermont Agency of Digital Services (ADS) meets the biennial ADP system security review requirement on behalf of Vermont Agency of Human Services (AHS) via an IRS Security Audit (cadency of every three years) and by contracting with 3rd party security risk assessment firms like JANUS Associates. Both audits use the same standard IRS Publication 1075 which is built on the NIST standard 800-53 revision 5. Over the last year the DCF IT Maintenance & Operations (M&O) Team has provided the IRS two CAP updates for the finding related to the last IRS audit. There is expected to be an overlap between the findings of the last IRS Audit and those identified by JANUS and ADS will complete a cross reference analysis between these two audits by the end of this calendar year. If there are any findings that are unique to JANUS (i.e., not identified in the IRS audit), a CAP will be documented for the finding by the end of this calendar year. An experienced IT Specialist on the DCF IT M&O Team has been assigned to lead this compliance project. Scheduled Completion Date of Corrective Action Plan: December 31, 2023: CAP to be documented. TBD: Documented CAP to be completed. Contacts for Corrective Action Plan: Michael Blanchard, ADS IT Manager michael.blanchard@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov
Finding 384904 (2023-027)
Significant Deficiency 2023
The case was mistakenly closed on 6/30/23 based on non-response to an income verification request. A verification notice was sent 6/12/2023. The member did not respond to this notice. The member should then have received notice of termination effective 7/31/2023. The case was not processed for clos...
The case was mistakenly closed on 6/30/23 based on non-response to an income verification request. A verification notice was sent 6/12/2023. The member did not respond to this notice. The member should then have received notice of termination effective 7/31/2023. The case was not processed for closure and appropriate notice was not sent because a system error caused this member to be classified as a new applicant instead of enrollee. This was likely due to case-specific circumstances of timing and household eligibility (other members were no longer eligible for Medicaid). Further, because they were classified as a new applicant, they received an additional verification notice (even though coverage was already terminated) and were ultimately “denied” for non-response in late July. As corrective action, we reinstated CHIP back to 7/1/2023 through 10/31/2023 after sending proper closure notice for failure to respond. Based on our internal QA process, Medicaid Recon and HCQC unit’s internal case reviews, no other incidents of this condition were found as of 10/2/2023. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Nicole McAllister, DVHA-HAEEU HCAA II nicole.mcallister@vermont.gov Sarah York, DVHA-HAEEU HCAA I sarah.york@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov
The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements tha...
The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Please note that the scheduled completion date is 2/1/23 as the same FFATA reporting finding was identified for a different program during the SFY22 Single Audit, and the corrective action plan was applied across the Department as a whole. The FFATA issues identified in the SFY23 Single Audit pre-dated the implementation of our corrective action plan. Scheduled Completion Date of Corrective Action Plan: 2/1/2023 Contacts for Corrective Action Plan: Lillian Smith, VDH Financial Administrator lillian.smith@vermont.gov Jessica Brown, VDH Financial Manager jessica.p.brown@vermont.gov Megan Hoke, VDH Financial Director megan.hoke@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov
Finding 384895 (2023-021)
Significant Deficiency 2023
Due to staff vacancies and turnover that arose in the DCF Quality Assurance & Reporting (QA&R) team during the summer of 2022, there was insufficient intra-team communication and training regarding FFATA reporting requirements. As of January 1, 2024, then, formal procedures and training will be put...
Due to staff vacancies and turnover that arose in the DCF Quality Assurance & Reporting (QA&R) team during the summer of 2022, there was insufficient intra-team communication and training regarding FFATA reporting requirements. As of January 1, 2024, then, formal procedures and training will be put in place to ensure all QA&R staff are prepared to execute their responsibilities pertaining to FFATA reporting requirements. Further, in order to monitor FFATA reporting compliance going forward, AHS Internal Audit Group (IAG) will include LIHEAP subawards in its annual review. Scheduled Completion Date of the Corrective Action Plan: January 1, 2024: FFATA reporting procedures and training in place and operating. December 31, 2024: Annual review of FFATA rules and regulations including subawards review. Contacts for Corrective Action Plan: Melanie Rutledge, DCF Financial Director I melanie.rutledge@vermont.gov Megan Smeaton, DCF Financial Director IV megan.smeaton@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov
The Agency has started implementing this process July 1, 2023 as a component of last year’s corrective action plan. The Agency will identify if a new ESEA Federal grant (or a grant based on an ESEA program) includes an Equitable Service requirement during the program completion of the “New Grant ...
The Agency has started implementing this process July 1, 2023 as a component of last year’s corrective action plan. The Agency will identify if a new ESEA Federal grant (or a grant based on an ESEA program) includes an Equitable Service requirement during the program completion of the “New Grant Checklist”. If a new grant includes an Equitable Service requirement, the ESEA Equitable Service’s Ombudsman will be notified and will work with the grant program manager to ensure the build of the GMS application includes the correct level of detail and controls to meet the SEA requirements for oversight. When appropriate, the Agency will use its process for handling of Equitable Services associated with the Consolidated Federal Programs as models for determining the correct calculation method. The Agency will utilize built in business rules and internal controls within the Grants Management System (GMS) to gather the following information in the grant application for AOE review and approval prior to issuing a grant award agreement: 1. Calculation of the total proportionate share dollars an LEA must set aside for Equitable Services 2. Identification of Independent Schools participating in Equitable Services applicable to each LEA 3. Calculation of the dollars available for Equitable Services for each participating Independent School For each Federal grant that requires an equitable services component, the Agency will document the review and approval of the Equitable Services information through one of two processes prior to the grant award agreement: 1. A dedicated review assignment specific to equitable services, or 2. Verification statements on the review checklist for a general application reviewer Position Responsible for Implementation of Corrective Action Name: Deborah Bloom, Assistant Director, Federal and Education Support Programs Position: Assistant Director Email: deborah.bloom@vermont.gov Phone Number: 802-828-1390 Date of Implementation of Corrective Action: July 1, 2023
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we s...
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year. The work will be done by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024
Finding 384875 (2023-016)
Significant Deficiency 2023
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we s...
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year. The work will be done by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024
The Department is currently undergoing a division and business unit wide analysis of our internal controls and procedures. As part of that effort, the Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that report...
The Department is currently undergoing a division and business unit wide analysis of our internal controls and procedures. As part of that effort, the Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. Cameron Wood, UI Director, Cameron.Wood@vermont.gov Scheduled Completion Date of Corrective Action Plan: August 31, 2024
Finding 384836 (2023-003)
Significant Deficiency 2023
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system.  This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we s...
To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system.  This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year.  The work will be done by the Deputy CFO or position assigned by the Deputy CFO.   We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024
WAID management will consider documenting its policies and procedures in the event duties need to be transitioned.
WAID management will consider documenting its policies and procedures in the event duties need to be transitioned.
Compensating controls are believed to be in place to effectively mitigate risks involved with cash disbursements. WAID will also consider compensating controls to effectively mitigate the risks surrounding cash receipts and cash management. These controls will include: • The review and reconcili...
Compensating controls are believed to be in place to effectively mitigate risks involved with cash disbursements. WAID will also consider compensating controls to effectively mitigate the risks surrounding cash receipts and cash management. These controls will include: • The review and reconciliation of monthly cash receipts to the bank statements by a member of the Board.
Finding #2023-001 - Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a...
Finding #2023-001 - Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: Controls Over Accounts Payable/Disbursements 1. Person processing accounts payable is not always separate from those who print the checks. Controls Over Payroll 1. Person preparing the payroll is not independent of other personnel duties such as custody of the checks and reconciling the bank statements. Criteria: Internal controls should be in place that provide adequate segregation of duties. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the distiict's operations. Response: We agree with this finding but due to the size of our District and financial constraints we do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Principal at the High School or Elementary/Middle School approves monthly accounts payable checks and the Depaiiment Head or P1incipal approves payroll timesheets prior to processing payroll. The Principals and Department Heads will continue to monitor transactions of the District.
Management’s Response: The initial grant agreement totaled $500,000. With the success of the program, the grant agreement was modified increasing the total to beyond the $750,000 threshold requiring a Single Audit. The Administrator of the grant was unfamiliar with the Single Audit requirement hav...
Management’s Response: The initial grant agreement totaled $500,000. With the success of the program, the grant agreement was modified increasing the total to beyond the $750,000 threshold requiring a Single Audit. The Administrator of the grant was unfamiliar with the Single Audit requirement having not previously managed Federal funds of this amount. Upon questioning from the Organization’s Accountant, the Administrator inquired with and was directed by the Department of Education that a Single Audit was required due to the total funds received during FY2023 under this grant exceeding $750,000. Future agreements will be reviewed by the Administrator to identify specific accounting requirements surrounding federal funding. Referral to the Organization’s Accountant for review of such agreements will be done if appropriate.
FINDING 2023-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Equipment purchased with ESF grant awards, although accounted for in the capital asset listing, were not properly identified with the source of the funding, who hold...
FINDING 2023-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: Equipment purchased with ESF grant awards, although accounted for in the capital asset listing, were not properly identified with the source of the funding, who holds title, percentage of federal participation in the project costs, etc. Contact Person Responsible for Corrective Action: Debra Elder, Treasurer and John Scioldo, Superintendent Contact Phone Number and Email Address: 812-547-3300; debbie.elder@tellcity.k12.in.us and john.scioldo@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will reach out to AdTec, the company the school corporation works with on the updating of the capital asset records, to request that they add the missing information to the capital asset listing for said purchased equipment as described in greater detail in the audit finding. It is our goal to have this completed by the end of the July 2023 – June 2025 audit cycle. Anticipated Completion Date: No later than June 30, 2025
FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Special Tests and Provision – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The finding was isolated to school year 2023 in which one employee is to determine the number of applications to be verified, selec...
FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Special Tests and Provision – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The finding was isolated to school year 2023 in which one employee is to determine the number of applications to be verified, select the required applications and perform verifications of eligibility, with a second employee reviewing the verifications. Contact Person Responsible for Corrective Action: Kathy VanHoosier, ECA Manager Contact Phone Number and Email Address: 812-547-3300; kathy.vanhoosier@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The process of selecting and performing verifications of eligibility with a second employee reviewing the verifications was refined and fully implemented for school year 2023/2024. A change in personnel since the 2022/2023 improved this process, and sign-offs were done and initialed by both the initial reviewer (the Central Office manager) as well as the final reviewer (the ECA Manager) on the 2023/24 applications. It is the intent to continue with this improved internal control process going forward. Anticipated Completion Date: Already Done in Fall 2023
2023-002 Section 8 Project-Based Cluster – Assistance Listing No. 14.249/14.182 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be follo...
2023-002 Section 8 Project-Based Cluster – Assistance Listing No. 14.249/14.182 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure property management staff is properly trained and supervised to ensure eligibility determinations are completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
2023-006 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Explanation of disagreement with audit finding: There is no disagreement with the audit f...
2023-006 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their PIC upload process to ensure that all certifications are properly uploaded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Public and Assisted Housing Compliance Officer will ensure the PIC upload process is done properly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
2023-005 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Explanation of disagreement with audit finding: There ...
2023-005 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their reasonable rent determination process to ensure that it is performed before the rent is set to go into effect. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure staff perform the rent reasonableness determination prior to the effective date. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
View Audit 297906 Questioned Costs: $1
2023-004 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process fo...
2023-004 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their inspection process to ensure that they are performed timely and that all documentation is maintained within Yardi. We recommend the Authority review their process for abatement/enforcing family obligations to ensure timely correction and enforcement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure the inspection process in performed timely and the documentation is maintained within the Yardi software program. Processes will be reviewed and updated to ensure timely correction and enforcement. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
View Audit 297906 Questioned Costs: $1
2023-003 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their pr...
2023-003 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their recertification process to ensure that all Eligibility requirements are met and all necessary documentation is maintained. We recommend the Authority review their processes to ensure that the HAP calculated on the HUD-50058 is the amount paid to the landlords. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure staff is properly trained to ensure the recertification process is completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
View Audit 297906 Questioned Costs: $1
2023-001 Low-Rent Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when comple...
2023-001 Low-Rent Public Housing – Assistance Listing No. 14.850 Recommendation: We recommend the Authority reinforce the individuals completing eligibility determinations with additional training and supervision as well as re-emphasize the controls and procedures that should be followed when completing the determinations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure property management staff is properly trained and supervised to ensure eligibility determinations are completed correctly. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: June 30, 2024
Management Response and Corrective Action Plan CRRUA has not previously required a single audit under Uniform Guidance, CRRUA will work with DAC Grant and Accounting team, who assist in oversight per contract agreement, to develop written procedures and policies per Uniform Guidance requirements. I...
Management Response and Corrective Action Plan CRRUA has not previously required a single audit under Uniform Guidance, CRRUA will work with DAC Grant and Accounting team, who assist in oversight per contract agreement, to develop written procedures and policies per Uniform Guidance requirements. In addition, CRRUA will enlist external assistance for additional review and recommendations regarding the drafted policies and procedures. Finding resolved timeline: Implemented by June 30, 2024. In the next 3 months CRRUA will implement policies and procedures required to conform with Uniform Guidance. Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, (Interim) Executive Director and Mary DeAvila, Office Manager
Management Response and Corrective Action Plan CRRUA had an oversight issue with identifying the federal components of the state grants/loans. CRRUA will implement recommendations and all grants with federal funding will be identified with Assistance Listing #. In addition, CRRUA will confirm with ...
Management Response and Corrective Action Plan CRRUA had an oversight issue with identifying the federal components of the state grants/loans. CRRUA will implement recommendations and all grants with federal funding will be identified with Assistance Listing #. In addition, CRRUA will confirm with Grant and Loan agencies during the agreement process to determine if federal funding is involved, so that CRRUA follows Uniform Guidance Requirements for Federal Awards. Prior to signing a grant or loan, the (Interim) Executive Director will identify the type of grant and loan so that appropriate reporting measure is in place for federally funded grants and loans. Finding resolved timeline: Immediately for current grants and loans and with a process in place for federal identification of future grants and loans. Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, (Interim) Executive Director
Action taken in response to finding: • LMC staff will institute a monthly review of ten self-pay encounters and will provide training to staff as needed.
Action taken in response to finding: • LMC staff will institute a monthly review of ten self-pay encounters and will provide training to staff as needed.
Condition: The University did not have documented controls in place, reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023 Corrective Action Planned:The University will reevaluate procedures to ensure t...
Condition: The University did not have documented controls in place, reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023 Corrective Action Planned:The University will reevaluate procedures to ensure that all reports required under Uniform Guidance are reviewed, approved, documented, and retained in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action: Richard Thomas, Senior Director of IT Informational Technology, and Paul Matson, CFO & VP of Finance
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