Corrective Action Plans

Finding 537368 (2024-013)

Significant Deficiency 2024

State of Vermont

VT

Questioned Costs Cash Management Matching / Level of Effort / Earmarking § 200.303 § 200.343

Reference Number: 2024-013 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Federal Transit Cluster Assistance Listing Number: 20.500, 20.507, 20.526 Award Number and Year: VT-04-0021-01 (3/14/2013 – 6/30/2016) Complianc...

Reference Number: 2024-013 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Federal Transit Cluster Assistance Listing Number: 20.500, 20.507, 20.526 Award Number and Year: VT-04-0021-01 (3/14/2013 – 6/30/2016) Compliance Requirement: Cash Management, Period of Performance Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that VTrans review and enhance grant closeout procedures and internal controls to ensure that grants are closed out timely. We further recommend that VTrans review and enhance procedures and internal controls over cash management to ensure that cash draws are performed only against grants for which the period of performance has not expired. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The following factors contributed to the noncompliance: VTrans experienced staff turnover, at which point close out processes were missed in 2016. This resulted in a grant remaining with an open status in the TrAMS system well beyond the period of performance. During the 2024 review by program staff, a drawdown was inadvertently processed for this grant with the expired period of performance. At the time, VTrans lacked a formal, documented grant closeout process for FTA grants in the TrAMS system. Additionally, there was a breakdown in communication between the Accounts Receivable (AR) team and the Public Transit Program team regarding period of performance eligibility prior to processing the draw. VTrans has taken the following steps to strengthen internal controls and prevent recurrence of this issue: 1. Formalized Closeout Procedures: VTrans has implemented a structured grant closeout process for the AOT Public Transit Program that clearly defines responsibilities, timelines, and verification steps to ensure all federal awards are closed timely and in compliance with FTA requirements. This process assigns specific tasks to designated staff members and ensures that no drawdowns occur after the period of performance has ended. 2. Annual Period of Performance Review: VTrans has established and documented an annual review process for FTA grant periods of performance. This review has been formally integrated into the Agency’s Public Transit cash management procedures, ensuring that grant end dates are proactively monitored, and necessary extensions or closeouts are addressed before expiration. 3. Enhanced Communication and Documentation: VTrans has updated the internal Excel file used to facilitate communication between the Public Transit Program team and the AR team. The file now includes a designated column for period of performance, ensuring that all drawdowns are reviewed for eligibility before processing. This is also addressed in an update to the Agency’s Public Transit cash management procedure memo. VTrans will coordinate with FTA to determine the appropriate resolution for these funds. Any necessary repayment or adjustments will be completed in accordance with FTA guidance. At this time, FTA has not requested the funds be returned. Scheduled Completion Date of Correction Action Plan: All corrective actions will be implemented as of March 1, 2025. Contacts for Corrective Action Plan: Ross MacDonald, Public Transit Director ross.macdonald@vermont.gov

View Audit 348596 Questioned Costs: $1

Finding 537367 (2024-012)

Significant Deficiency 2024

State of Vermont

VT

Matching / Level of Effort / Earmarking Special Tests & Provisions Significant Deficiency § 200.303

Reference Number: 2024-012 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Special Tes...

Reference Number: 2024-012 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance procedures and internal controls to ensure that it obtains weekly certified payrolls from all contractors. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Daily Work Reports (DWRs) submitted by the contractor concluded the outstanding punchlist items in June 2023, and in September 2023 a subcontractor submitted a DWR to AOT. The project went through Completion and Acceptance (C&A) in December 2023. The C&A process required confirmation that payrolls were received but did not include a final complete-verification step before project closeout. As a result, missing payroll certifications went unnoticed. Additionally, the Civil Rights team was unaware of the subcontractor’s work report since their review is triggered by certified payroll submissions, not DWRs. VTrans is updating the C&A checklist to require final confirmation that all certified payrolls have been received before project closeout, with coordination from the Civil Rights team if any are missing. This checklist is to be verified by both the Resident Engineer and the Regional Engineer. To further strengthen compliance, VTrans Construction will focus on education, and revise pre-construction meeting templates to emphasize that federal wage reporting requirements apply to all work on a project. Additionally, VTrans Civil Rights will reinforce these requirements in annual contractor training to ensure Prime and Subcontractors fully understand their payroll reporting responsibilities. VTrans will also remain cognizant of projects and DWRs submitted by new subcontractors and actively work to educate contractors at this point to prevent future payroll omissions. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of April 1, 2025. Contacts for Corrective Action Plan: Douglas Bonneau, VTrans Construction Engineer douglas.bonneau@vermont.gov

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Finding 537362 (2024-010)

Significant Deficiency 2024

State of Vermont

VT

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

Reference Number: 2024-010 Prior Year Finding: 2023-008; 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A6...

Reference Number: 2024-010 Prior Year Finding: 2023-008; 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Scheduled Completion Date of Corrective Action Plan: April 1, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov

View Audit 348596 Questioned Costs: $1

Finding 537361 (2024-009)

Significant Deficiency 2024

State of Vermont

VT

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

Reference Number: 2024-009 Prior Year Finding: 2023-007; 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance...

Reference Number: 2024-009 Prior Year Finding: 2023-007; 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the Department reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are supported and reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are adequately reviewed and signed off on. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. Scheduled Completion Date of Corrective Action Plan: April 1, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov

View Audit 348596 Questioned Costs: $1

Finding 537360 (2024-008)

Material Weakness 2024

State of Vermont

VT

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

Reference Number: 2024-008 Prior Year Finding: 2023-005; 2022-012; 2020-009 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: State UC, UCFE, UCX, TRA UI393002355A50 (10/202...

Reference Number: 2024-008 Prior Year Finding: 2023-005; 2022-012; 2020-009 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: State UC, UCFE, UCX, TRA UI393002355A50 (10/2022-9/30/2023), TRA 24A55UT000024 (10/1/2023-9/30/2024), RESEA UI380102260A50 (1/1/2022-9/30/2024) RESEA 23A60UR000010 (1/1/2023-9/30/2025), Admin UI393532355A50 (10/1/2022-12/31/2025), Admin 24A55UI000063 (10/1/2023-12/31/2026), ARPA Fraud UI370952155A50 (9/1/2021-8/31/2025), ARPA Equity UI370952155A50 (10/1/2022-10/31/2025), CARES UI347462055A50 (4/1/2021-6/30/2025), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend that policies and procedures be implemented to ensure that all financial and performance reports are accurate, agree with supporting documentation, and are reviewed by an authorized State official prior to submission. We also recommend that supporting documentation and evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: 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. Scheduled Completion Date of Corrective Action Plan: June 30, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov

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Finding 537359 (2024-007)

Significant Deficiency 2024

State of Vermont

VT

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Period: W912LN2421001 (10...

Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Period: W912LN2421001 (10/1/2023 – 9/20/2024) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department agrees with this finding and will implement the following: • Update Accounts Payable Standard Operating Procedures to include instructions for determining the appropriate Federal Fiscal year for coding and paying vendor invoices. • Distribute updated procedures and train staff to ensure understanding of Period of Performance reporting requirements. • Update Vision query to include the Invoice Date field. Current reports used for preparing the SF-270 only include the Vision transaction date, therefore the preparer and reviewer are not able to determine the performance dates of individual transactions based on this report alone and rely on proper coding of the Class field during voucher entry. Adding the Invoice Date to the report will improve the department’s ability to QC the SF-270 for period of performance discrepancies prior to submission for reimbursement. • The Financial Director will perform quarterly audits of this Vision report to identify any improper reporting. Any errors identified will be corrected with a journal voucher and subsequently corrected on the next SF-270. Scheduled Completion Date of Corrective Action Plan: April 15, 2025 Contacts for Corrective Action Plan: Kim Fedele, Financial Director kimberly.fedele@vermont.gov

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Finding 537342 (2024-026)

Significant Deficiency 2024

State of Vermont

VT

Questioned Costs Cash Management Reporting § 200.303 § 200.514

Reference Number: 2024-026 Prior Year Finding: 2023-023 Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Finance and Management Federal Program: SNAP Cluster Temporary Assistance for Needy Families CCDF Cluster Assistance Listing...

Reference Number: 2024-026 Prior Year Finding: 2023-023 Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Finance and Management Federal Program: SNAP Cluster Temporary Assistance for Needy Families CCDF Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.575, 93.596 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that Finance review and enhance its internal controls and procedures over the CMIA Annual Report to ensure that it verifies the correct interest rate is applied and that State and Federal interest liabilities are properly calculated in accordance with 2 CFR section 200.514. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The current available rate at the time of calculation, review, entry, and moving to draft were all accurate to what U.S. Treasury had available at the time. The rate was updated on December 3rd, after our submissions had already been locked via the draft process in the CMIAS portal done on November, 26th. The process was not fully submitted due to issues with the CMIAS portal not allowing us to submit which has been extensively documented via multiple email chains with U.S. Treasury CMIA over the past two years. Finance and Management will take a screenshot of the CMIA interest rate page dated on the review date of the CMIA Annual Report submissions from departments to ensure that we maintain the historical rate posted to the U.S. Treasury CMIA page at the time of review. Additionally, AHS will take their own screenshots of the CMIA Interest Rate page from U.S. Treasury website on the date of their Annual Report Summary submissions for record and to show that the rate from this time was checked and applied to the current year’s program. If during the review, there is any discrepancy between the review screen of the rates and the calculations screenshot of the rates; the calculation spreadsheets will be kicked back to AHS to be updated. Scheduled Completion Date of Corrective Action Plan: November 30, 2025 Contacts for Corrective Action Plan: Jordan Black-Deegan, Statewide Grants Administrator jordan.black-deegan@vermont.gov Sarena Boland, Financial Manager III sarena.boland@vermont.gov

View Audit 348596 Questioned Costs: $1

Finding 537340 (2024-005)

Significant Deficiency 2024

State of Vermont

VT

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) C...

Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Special Tests and Provisions – EBT Card Security Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that the Agency review and enhance internal controls to ensure that it maintains documentation of the daily/weekly reconciliation of destroyed EBT cards. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Cards were automatically printing at 1:00 AM which presented many opportunities for errors. The printers can only hold 100 cards in their hoppers and only print on one printer at a time. If there were more than 100 cards to be printed the printer(s) would error out and subsequently drop cards from the print file and/or print duplicates when the errors were corrected once someone was in the office. We have now updated the print jobs to print at 9:00 AM when a trained EBT staff member is there to monitor the printing. Additionally, we have a system in place to rotate printing on the 3 printers monthly to spread the wear and tear evenly. Increases to opened card inventory, decreases in the opened card inventory due to printing, and decreases in the opened card inventory due to shredded cards are included on the daily “Card Count” Excel that is then converted to a PDF for signatures through DocuSign. This daily “Card Count” Excel is updated and verified by EBT personnel to ensure that the remaining opened card inventory is reflective of what was added to the opened card inventory, what was printed, and what was shredded. Printed card counts on this “Card Count” Excel and PDF will be reflective of the daily “EBT Printing Reports” that are auto generated and e-mailed to the EBT staff. When there are excessive shredded cards (more than 5) EBT personnel will create a detailed e-mail to verify the day’s events with IT personnel. Once verified by the IT personnel, the e-mail will be a part of the DocuSign packet for the “Card Count” PDF to explain and backup the events from that particular day. The “Card Count” Excel and PDF is produced by the EBT staff person in the office to physically oversee that day’s printing. EBT staff rotate days that they are in the office; meaning that the EBT Financial Manager and the Financial Director of Operations verify that the rolling count is correct each week on Thursday’s and Wednesday’s (respectively) as they are in the office to process the printed cards. Scheduled Completion Date of Corrective Action Plan: EBT personnel have implemented the above e-mail attachment to the “Card Count” PDF solution as of November 2024. Contacts for Corrective Action Plan: Katherine Lettieri, Financial Manager III katherine.lettieri@vermont.gov Kristina Roy, Admin Services Coordinator I kristina.roy@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

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Finding 537339 (2024-004)

Material Weakness 2024

State of Vermont

VT

Questioned Costs Eligibility Reporting § 200.303

Reference Number: 2024-004 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) C...

Reference Number: 2024-004 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP 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 eligibility case reviews are performed timely and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: In the past year, the Economic Services Division has been slightly restructured with the creation of six new District Director Positions. This change is a positive one as it provides additional support in the districts and also allows the central office Operations team to focus more on systems and closer collaboration with programs to ensure clear communication and training for field staff. This change has resulted in a further need to clearly define the roles and expectations of the District Director positions compared to the Operations staff. One highlighted area relevant to this corrective action plan is updates to the Supervisory Case Review (SCR) Guide to clearly delineate roles and responsibilities and ensure that SCRs are completed timely and completely. The SCR Guide has been updated accordingly. Further corrective action includes: • Presentation of the SCR audit findings and updated SCR Guide by Operations and the Food and Nutrition team to District Directors and Supervisors. • Creation by the Food and Nutrition team of training for Supervisors and District Directors about the SCR process. This training will be presented at the next District Directors meeting on 3/12/2025 as well as at the ESD Division Leadership meeting on 3/21/2025 to Supervisors. • Requirement for all newly hired District Supervisors or Directors to complete the SCR Training. This training will be mandatory for all staff who are required to complete monthly Supervisory Case Reviews and tracked through the Learning Management System. Scheduled Completion Date of Corrective Action Plan: March 21, 2025 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager jessica.duranleau@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596 Questioned Costs: $1

Finding 537338 (2024-003)

Material Weakness 2024

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Reference Number: 2024-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: AM200100XXXXG081 (9/30/2020 – 9/30/2024), 21DBIVT1004 (...

Reference Number: 2024-003 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: AM200100XXXXG081 (9/30/2020 – 9/30/2024), 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), 23DBIVT1018 (9/30/2023 – 9/29/2026) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency develop procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to FSRS in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: April 30, 2025 Contacts for Corrective Action Plan: Amy Mercier, Financial Director amy.mercier@vermont.gov Karen Mae Smith, Financial Director karenmae.smith@vermont.gov

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Finding 537336 (2024-006)

Significant Deficiency 2024

East Central University

OK

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The ECU Registrar is creating a new work manual for National Student Clearinghouse (NSC) enrollment reporting, which will correctly outline how Colleague handles enrollment status rules. The ECU Registrar will personally generate each NSC file from Colleague. A member of the Registrar's team will co...

The ECU Registrar is creating a new work manual for National Student Clearinghouse (NSC) enrollment reporting, which will correctly outline how Colleague handles enrollment status rules. The ECU Registrar will personally generate each NSC file from Colleague. A member of the Registrar's team will continue to address error report, and also will perform the data checks discussed below. Prior to each NSC enrollment reporting date, the fields in Colleague screen ACLV will be verified as accurate by the Registrar. Each time an NSC enrollment report is generated, but before it is submitted to the Clearinghouse, the following data checks will be performed. Confirm students are showing in the enrollment file for each enrollment status. Spot-check at random 10 students within each enrollment status category to verify statuses are calculating correctly. Compare NSC numbers with ECU institutional enrollment numbers for graduate and undergraduate overall enrolled. ECU has reviewed enrollment submissions through Spring 2025 and will make manual corrections.

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Finding 537334 (2024-005)

Significant Deficiency 2024

East Central University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Counselors will utilize a Verification check sheet to show their work on verifications and corrections made on FAFSA Processing System (FPS). Counselors will be required to track and verify that the corrections were made appropriately on FPS by verifying those corrections on the updated ISIR. A comm...

Counselors will utilize a Verification check sheet to show their work on verifications and corrections made on FAFSA Processing System (FPS). Counselors will be required to track and verify that the corrections were made appropriately on FPS by verifying those corrections on the updated ISIR. A communication code will be created so that the counselors can track when a correction is made and when the corrected ISIR is received and verified correctly. The Director and Assistant Director can then run lists of all students with the particular communication code to spot-check and review.

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Finding 537332 (2024-004)

Significant Deficiency 2024

East Central University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Changes to COA for a student are documented and reviewed by the Assistant Director or the Director. A report will be created to view disbursement dates in Colleague and COD to find variances in the dates. This report will be processed weekly. The counselor, Assistant Director, or Director will revie...

Changes to COA for a student are documented and reviewed by the Assistant Director or the Director. A report will be created to view disbursement dates in Colleague and COD to find variances in the dates. This report will be processed weekly. The counselor, Assistant Director, or Director will review disbursements in COD to verify that the COA and disbursement date agree with Colleague.

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Finding 537330 (2024-003)

Significant Deficiency 2024

East Central University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

The process to determine students who withdraw during the semester has been updated to include running a withdrawal list through RGER weekly. The list will be given to the Financial Aid Counselors to work on Mondays. Part of the review will be to verify the start and end dates of the term used duri...

The process to determine students who withdraw during the semester has been updated to include running a withdrawal list through RGER weekly. The list will be given to the Financial Aid Counselors to work on Mondays. Part of the review will be to verify the start and end dates of the term used during the process. The Director or Assistant Director will review the lists and R2T4 forms (ROFW) to verify accuracy and timely processing.

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Finding 537328 (2024-002)

Significant Deficiency 2024

East Central University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Loan notification letters/emails to students and/or parents were set up and made operational in July 2024 with the assistance of a consultant. Further updates/changes were made in August 2024.

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Finding 537324 (2024-003)

Material Weakness 2024

Southwestern Consolidated School District of Shelby County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or O...

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Condition and Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation had one project for roof repairs that was funded with ESSER III (84.425U) grant awards and was subject to the Davis-Bacon requirements. The School was not able to provide an executed contract containing the required wage rate requirements clause, nor did the School obtain the required weekly certified payroll reports from the contractor to monitor compliance with Davis-Bacon wage rate requirements. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The total project cost disbursed during the audit period was $443,300, which included materials and labor. Contact Person Responsible for Corrective Action: Jamison Wilkins Contact Phone Number: 317-729-5746 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: On September 18, 2024 a corrective action plan was submitted to and approved by the USDE. That action plan included that attestation that the superintendent had watched the necessary webinars and will meet Davis-Bacon requirements on all future projects. Anticipated Completion Date: Resolved

View Audit 348592

Finding 537320 (2024-005)

Material Weakness 2024

Southwestern Consolidated School District of Shelby County

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers)...

Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the cash management compliance requirement. During the testing of claim reimbursements, we noted for two monthly reimbursements in a sample of six claims that the claim reimbursements were not being reviewed by an independent individual before being submitted to IDOE. In March 2023, the School Corporation implemented a review control over the monthly claim reimbursement. The lack of controls was isolated to the period of July 2022 through February 2023 during fiscal year 2023. For all six claims tested, we agreed the number of meals claimed for reimbursement to underlying meal system reports without exception. Contact Person Responsible for Corrective Action: Brisha Dunbar Contact Phone Number: 317-729-5122 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director Brisha Dunbar will complete the claims reimbursement form each month. Once completed it will be reviewed by the business manager for correct amounts before submitting the request for reimbursement. The FSD will print out the claims and both she and the reviewer will initial the form. Anticipated Completion Date: Ongoing, effective 03/24/2025

View Audit 348592

Finding 537314 (2024-001)

Material Weakness 2024

Tipton Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number and Email Address: (765) 675-2147 Ext 3316; bcleaver@tcsc.k12.in.us Views of Responsible Officials: We conc...

FINDING 2024-001 (Auditor Assigned Reference Number) Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Brook Cleaver Contact Phone Number and Email Address: (765) 675-2147 Ext 3316; bcleaver@tcsc.k12.in.us Views of Responsible Officials: We concur that there was not a documented control in place to ensure that timely eligibility determinations were made for direct certification eligibility determinations. Description of Corrective Action Plan: Etrition is our new system for the 2024-25 school year. Weekly, Susie Moore, kitchen manager, checks the state website for any direct certification file pulls. The file is saved by date and is used to import direct certs into the Etrition program on that same day. Each Friday, eligibility determination notices are issued via email to the parent or guardian email listed in the school’s information system, Powerschool. If such an email does not exist in the information system, a hard copy of the notice is mailed to the household. Duplicate copies will be retained in our files. Etrition syncs with PowerSchool at midnight each day successfully changing student lunch statuses. Benefit notifications will be reviewed by a second person and checked against the direct cert file pull to verify for accuracy. Income applications will work in a similar fashion, wherein we will retain evidence of the eligibility notices being sent to households. A binder of all notices will be kept on file. Anticipated Completion Date: Immediately - 3/4/2025

View Audit 348580

Finding 537313 (2024-002)

Significant Deficiency 2024

Spalding University

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Identifying Number: 2024-002 Finding: Federal Program: U.S. Department of Education - Student Financial Aid Cluster: Federal Direct Loan Program, 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of unoﬃcial withdrawals and stu...

Identifying Number: 2024-002 Finding: Federal Program: U.S. Department of Education - Student Financial Aid Cluster: Federal Direct Loan Program, 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of unoﬃcial withdrawals and student status changes for graduates, we selected four and 22 samples, respectively, and we noted one instance in each testing section where a student’s status change was not timely reported to the National Student Loan Database System (NSLDS). Cause: The University did not have controls in place to ensure students' classiﬁcation were being properly reported to the NSLDS. Eﬀect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported timely and subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this ﬁnding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster ﬁles are submitted to the NSLDS. In addition, we recommend that the University submit roster ﬁles on a regular basis. Corrective Actions Taken or Planned: Regarding the status change for the identiﬁed graduate, management implemented a new process for reporting student enrollments. The Oﬃce of Institutional Research reviews the speciﬁcations for reporting from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to ensure that the proper data is being reported. Reports are generated by Institutional Research and upon approval of the Registrar submitted to the NSC. Any errors are remediated by the Registrar. And the Financial Aid Oﬃce veriﬁes that reports sent to the National Student Clearinghouse are accurately reported to the National Student Loan Data System, by auditing both systems with assistance from the Oﬃce of institutional Research and Oﬃce of the Registrar. This process was implemented in February 2023. However, the timing of that ﬁx occurred after the student in question had already graduated, meaning they were not included in the corrective measures. For the Return of Title IV (R2T4) calculation process, management has updated our procedures to ensure that student enrollment status is promptly updated when an R2T4 is completed. Speciﬁcally, a required step was added in the R2T4 process where a designated box is checked in the system, ﬂagging the student’s account for withdrawal status reporting. This change helps ensure timely and accurate reporting of enrollment status to NSLDS. Completion Date: October 1, 2024 Responsible Oﬃcial: Robert Giesting, Executive Director of Institutional Assessment and Learning

View Audit 348577

Finding 537308 (2024-001)

Material Weakness 2024

University of La Verne

CA

Special Tests & Provisions Student Financial Aid Material Weakness

Finding #: 2024-001 – Special Tests and Provisions – Return of Title IV Funds Description of Finding: One record from the return to Title IV sampling of 12 students tested, had funds returned beyond the required timeline for an unofficial withdrawal. The record received a non-completed course grade ...

Finding #: 2024-001 – Special Tests and Provisions – Return of Title IV Funds Description of Finding: One record from the return to Title IV sampling of 12 students tested, had funds returned beyond the required timeline for an unofficial withdrawal. The record received a non-completed course grade for the fall 2023 term, but the return of funds based on the unofficial withdrawal was not performed until July 2024. The cause of the delayed return was the irregular non-completed course grade that was applied by faculty. The grade type was not incorporated into control measures for prompt identification. The University of La Verne concurs with this finding. Corrective Action: The reporting criteria used to identify non-completed courses are being modified to include all grade codes that meet the non-completed criteria, regardless of their appropriateness to the enrollment type. This revision is to ensure that any irregular grade reporting would still be captured. Secondly, all staff who perform return to Title IV calculations are expected to complete the Federal Student Aid training modules on return to Title IV funds to reinforce the staff knowledge base. Lastly, with the recent onboarding of a Financial Aid Compliance Manager, additional quality assurance steps are being added to include random sampling and secondary review of return to Title IV records for accuracy and timeliness. The responsible party is Laura Evans at levans2@laverne.edu. This will be completed by December 2024.

View Audit 348574

Finding 537284 (2024-003)

Material Weakness 2024

North Gibson School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303 § 200.334 § 200.77 § 200.78

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies-Eligibility Contact Person Responsible for Corrective Action: Dr. Eric Goggins, Superintendent Contact Phone Number and Email Address: 812-385-4851; egoggins@ngsc.k12..in.us Views of Responsible Officials: We concur with ...

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies-Eligibility Contact Person Responsible for Corrective Action: Dr. Eric Goggins, Superintendent Contact Phone Number and Email Address: 812-385-4851; egoggins@ngsc.k12..in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: Not applicable Description of Corrective Action Plan: The food service director will do monthly eligibility reporting through the food service software to determine any free, reduced, paid, or direct certification eligibility changes. Change reports will be generated and provided to each building secretary on a monthly basis. Copies of each school’s eligibility changes will be provided to Marissa Breidenbaugh (HR Coordinator/Administrative Secretary) in the district office. Marissa will provide a deadline for all schools to update eligibility. On the deadline date, she will review each students Harmony demographics to ensure that the changes in eligibility have been recorded. The assistant superintendent will continue to develop the Title I application collaboratively with non-public schools. This development will include continued review of eligibility and enrollment data to ensure that it agrees with all supporting documentation. Anticipated Completion Date: This corrective action plan was implemented on March 3, 2025 and will continue to be implemented with the next Title I grant application process beginning approximately May 2025. INDIANA STATE

View Audit 348533

Finding 537245 (2024-002)

Significant Deficiency 2024

City of Fairfield

CA

Questioned Costs Matching / Level of Effort / Earmarking § 200.303 § 200.306 § 200.430

Matching, Level of Effort and Earmark Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance We concur. Corrective Action Plan: The City was not provided with payroll registers or pay stub copies for the in‐kind local match contribution from Solano County and the Travi...

Matching, Level of Effort and Earmark Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance We concur. Corrective Action Plan: The City was not provided with payroll registers or pay stub copies for the in‐kind local match contribution from Solano County and the Travis Community Consortium. However, the City did maintain hourly tracking for the two agencies when they attended meetings and used a lower pay rate, as outlined in the approved grant budget, when reporting back to the agencies. The required 10% in‐kind match was exceeded by $9,224.28, with a portion of the $30,000 mentioned above included in the excess match. Additionally, the grant had a pay rate cap of $87 for one of the County employees, so using the actual pay rate to calculate the in‐kind match was not permitted. The City will collaborate with the other agencies to obtain better documentation for the shared local match. Responsible Individual(s): Liz Aptekar, Assistant to the City Manager Anticipated Completion Date: To be completed by 6/30/2025

View Audit 348452 Questioned Costs: $1

Finding 537244 (2024-003)

Significant Deficiency 2024

Rider University

NJ

Questioned Costs Student Financial Aid Eligibility

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagr...

Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has strengthened its procedures to ensure student loan eligibility is reconciled after awarding. The Direct Loan project manager will conduct additional reviews to verify continued eligibility. Name(s) of the contact person(s) responsible for corrective action: Fatima Sulaman Planned completion date for corrective action plan: 3/17/25

View Audit 348448 Questioned Costs: $1

Finding 537241 (2024-001)

Significant Deficiency 2024

Rider University

NJ

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Federal Pell Grant Program & Federal Supplemental Education Opportunity Grants – Assistance Listing No. 84.063 & 84.007 Recommendation: We recommend the University implement policies to review all student award packages at the start of the academic year to ensure no over awards exist. In addition, ...

Federal Pell Grant Program & Federal Supplemental Education Opportunity Grants – Assistance Listing No. 84.063 & 84.007 Recommendation: We recommend the University implement policies to review all student award packages at the start of the academic year to ensure no over awards exist. In addition, we recommend the University implement procedures for adjusting aid when an outside scholarship is received by the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented enhanced procedures to review all student award packages at the start of the academic year to ensure compliacne with federal overaward regulations. Additionally, the new staff member that is responsible for adding outside scholarships to student accounts has received training to ensure they review for potential over awards. Name(s) of the contact person(s) responsible for correcitve action: Marivic Delacruz and Renato Aguilar Planned completion date for corrective action plan: 3/17/25

View Audit 348448 Questioned Costs: $1

Finding 530395 (2024-022)

Significant Deficiency 2024

State of Texas C/o Comptroller of Public Accounts

TX

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

Corrective action plan: TVC’s Finance Department hired a dedicated Budget Analyst to the VES program in October 2024. Both the Chief Financial Officer and the Deputy Chief Financial Officer will review and approve all Forecast and Payroll reports related to the VES grant program to ensure there is...

Corrective action plan: TVC’s Finance Department hired a dedicated Budget Analyst to the VES program in October 2024. Both the Chief Financial Officer and the Deputy Chief Financial Officer will review and approve all Forecast and Payroll reports related to the VES grant program to ensure there is proper documentation and approvals as well as to be familiar with procedures in the event of employee and/or management turnover. During the review process, the Chief Financial Officer or the Deputy Financial Officer will also validate that VES’s indirect revenues are being accurately calculated against VES’s payroll costs (salaries and benefits only) and well documented each month. There will also be an annual review conducted for additional verification. Implementation dates: November 2024 Responsible persons: Michelle Nall, Chief Financial Officer, Lawrence Cruz, Deputy Financial Officer, and Julie Pusan ,VES Budget Analyst

View Audit 348386 Questioned Costs: $1

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