Corrective Action Plans

Finding 385011 (2023-001)

None 2023

PR

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

Finding No. 2023–001 – Disbursement to or on behalf students Title IV, HEA credit balances Name of Contact Person: Dr. Ismael A. Velez de la Rosa Corrective Action Plan The University affirms its understanding of its obligation to submit disbursement according to the 34 CFR 668.164(h)(2)(i) A title ...

Finding No. 2023–001 – Disbursement to or on behalf students Title IV, HEA credit balances Name of Contact Person: Dr. Ismael A. Velez de la Rosa Corrective Action Plan The University affirms its understanding of its obligation to submit disbursement according to the 34 CFR 668.164(h)(2)(i) A title IV, a HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen (14) days after the balance occurred, if the credit balance occurred after the first day of class of a payment period. Due to an error in the system, within institutional officials in charge of managing this process, one disbursement was not submitted on a timely basis. UCB will reinforce their policies and procedures to satisfy all applicable requirements specified in 668.164 (h) and due a doble verification of the process to make sure every student no later than fourteen (14) days after the balance occurred. As of the date of the auditors’ report, the University request all of the institution’s officials to work in the school premises and the communication between officials has been improve, making easier the tracking of the disbursements on a timely basis to students. Anticipated completion date: Immediately.

View Audit 298066

Finding 384985 (2023-001)

Significant Deficiency 2023

Madison Area Technical College District

WI

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College design and implement controls to ensure reporting to NSLDS are designed to capture all enrolled students and programs offered by the District. Explanation of disagreement with audit...

Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the College design and implement controls to ensure reporting to NSLDS are designed to capture all enrolled students and programs offered by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District worked with NSC to resolve the errors surrounding mismatched CIP codes, resulting in the enrollment report being finalized in late 2022. The College will work with their Records Department to explore accommodations surrounding future term requirements. Name(s) of the contact person(s) responsible for corrective action: Laurie Grigg, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2024

View Audit 298033

Finding 384984 (2023-004)

Material Weakness 2023

Christian Theological Seminary, Inc.

IN

Eligibility Material Weakness Matching / Level of Effort / Earmarking

Planned Corrective Action: The Director of Financial Aid will document the review of students that change academic status (full time vs part time) and determine if any adjustments need to be made to the students Cost of Attendance as a result of the change. The Director of Financial Aid will docum...

Planned Corrective Action: The Director of Financial Aid will document the review of students that change academic status (full time vs part time) and determine if any adjustments need to be made to the students Cost of Attendance as a result of the change. The Director of Financial Aid will document this review and note any changes that were made as a result. If no changes are necessary, this will be documented as well Person Responsible for Corrective Action Plan: Sandra Mitchell Holder, Director of Financial Aid Anticipated Completion Date June 2024

View Audit 298024

Finding 384983 (2023-003)

Material Weakness 2023

Christian Theological Seminary, Inc.

IN

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

Planned Corrective Action: The Seminary has taken action on many security standards outlined in the Gramm-Leach-Bliley Act. However, the Seminary has not created a written comprehensive information security plan. The Seminary will develop this plan, that will incorporate many of the items that w...

Planned Corrective Action: The Seminary has taken action on many security standards outlined in the Gramm-Leach-Bliley Act. However, the Seminary has not created a written comprehensive information security plan. The Seminary will develop this plan, that will incorporate many of the items that we have already put in place. However, we realize with out a written plan that we are no incompliance with the Act. The Seminary will put the plan in writing. Person Responsible for Corrective Action Plan: Melissa Trayhan – Manager of Information Technology Anticipated Completion Date June 2024

View Audit 298024

Finding 384982 (2023-002)

Material Weakness 2023

Christian Theological Seminary, Inc.

IN

Eligibility Material Weakness Matching / Level of Effort / Earmarking

Planned Corrective Action: The Director of Financial Aid will document the calculation of Satisfactory Academic Progress. This calculation has occurred each year but the Seminary didn’t keep the documents that proved that the calculation was done and applied to each student. In the future, the ...

Planned Corrective Action: The Director of Financial Aid will document the calculation of Satisfactory Academic Progress. This calculation has occurred each year but the Seminary didn’t keep the documents that proved that the calculation was done and applied to each student. In the future, the Director of Financial Aid will keep detailed records of the calculation on each student and retain the records for audit purposes. Person Responsible for Corrective Action Plan: Sandra Mitchell-Holder – Director of Financial Aid Anticipated Completion Date: June 2024

View Audit 298024

Finding 384970 (2023-005)

Significant Deficiency 2023

Grants-Cibola County Schools

NM

Procurement, Suspension & Debarment Equipment & Real Property Management Matching / Level of Effort / Earmarking

Responsible Official’s Plan: Specific corrective action plan for finding: After receiving this finding during the previous audit, the District added language reflecting the Davis-Bacon requirements to all affected and qualified purchase orders. However, this was insufficient to meet the proper docum...

Responsible Official’s Plan: Specific corrective action plan for finding: After receiving this finding during the previous audit, the District added language reflecting the Davis-Bacon requirements to all affected and qualified purchase orders. However, this was insufficient to meet the proper documentation required by Davis-Bacon. The District (during SY23-24) began adding additional language, provided by our CPA, onto all qualifying CONTRACTS. We have reviewed all existing, qualifying agreements to add the appropriate language to all current agreements. The Coordinator for Procurement and Capital Projects will perform a double-check on all qualifying agreements issued moving forward. The Maintenance Department contacts the affected contractors to obtain the certified payroll reports for these projects. Timeline for completion of corrective action plan: This process has already been established and is in place. Employee position(s) responsible for meeting the timeline: Steve Maldonado Finance Director

View Audit 298006

Finding 384958 (2023-006)

None 2023

Vienna Public School District #55

IL

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

Name of Contact Person: Greg Frehner, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations Guidelines. Corrective Action: The auditors discussed the issue with the Distri...

Name of Contact Person: Greg Frehner, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations Guidelines. Corrective Action: The auditors discussed the issue with the District. A new checklist will be used with audit completion to ensure timely submission for the 2023 fiscal year. Proposed Completion Date: Immediately.

View Audit 297986

Finding 384924 (2023-034)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Public Assistance: Once a subaward has been executed and the cumulative obligated project worksheets have reached the $30,000 reporting threshold, then the Financial Administrator must enter the subaward in FSRS as outlined above. Subsequent project worksheet obligations shall be treated as award am...

Public Assistance: Once a subaward has been executed and the cumulative obligated project worksheets have reached the $30,000 reporting threshold, then the Financial Administrator must enter the subaward in FSRS as outlined above. Subsequent project worksheet obligations shall be treated as award amendments and must be entered into FSRS no later than the last day of the month following the month in which the project worksheet was obligated. Name: Richard Hallenbeck Position: Director of Administration/Finance Email: Richard.hallenbeck@vermont.gov Phone Number: 802 241-5339 Date of Implementation of Corrective Action: 03/31/2024

View Audit 297960

Finding 384922 (2023-033)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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: Completed 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

View Audit 297960

Finding 384918 (2023-032)

Significant Deficiency 2023

State of Vermont

VT

Questioned Costs Cash Management Significant Deficiency § 200.303 § 200.514

The Agency of Human Services receives funding under ALNs 93.775, 93.777, and 93.778 and is responsible for reporting the federal interest liability for these programs to the Department of Finance and Management. The Agency of Human Services previously relied on the Department of Finance and Manageme...

The Agency of Human Services receives funding under ALNs 93.775, 93.777, and 93.778 and is responsible for reporting the federal interest liability for these programs to the Department of Finance and Management. The Agency of Human Services previously relied on the Department of Finance and Management for notification of the annual interest rate. Going forward, the Agency of Human Services will obtain the annual interest rate directly from the CMIA website: Cash Management Improvement Act - Annual Interest Rates (treasury.gov). The Department of Finance and Management will also verify the Agency of Human Services’ submission prior to submitting the CMIA Annual Report to the US Department of the Treasury. Position Responsible for Implementation of Corrective Action Candace Elmquist Financial Director Candace.Elmquist@vermont.gov Peter Moino Director of Internal Audit Peter.Moino@vermont.gov Date of Implementation of Corrective Action: Completed: 2/6/2024

View Audit 297960 Questioned Costs: $1

Finding 384914 (2023-031)

Significant Deficiency 2023

State of Vermont

VT

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

1. With the 2022-37 Corrective Action Plan, Gainwell activated the termination job within the PMM that automatically ends a provider’s contract with VT Medicaid when no license was obtained by the license end date. This termination job was activated on 06/05/23. 2. With the 2022-37 Corrective Acti...

1. With the 2022-37 Corrective Action Plan, Gainwell activated the termination job within the PMM that automatically ends a provider’s contract with VT Medicaid when no license was obtained by the license end date. This termination job was activated on 06/05/23. 2. With the 2022-37 Corrective Action Plan, Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. The State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: 1. Completed 2. Completed Contacts for Corrective Action Plan: Deidra Jarvis, DVHA Member and Provider Services deidra.jarvis@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384910 (2023-030)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Agency of Human Services Internal Audit Group (AHS-IAG) is a designated centralized reporter of subawards for a Medicaid cluster (ALN 93.775, 93.777, 93.778) that is shared between all AHS departments. To address omissions and timeliness of subawards and subaward modifications reporting to FSRS, IAG...

Agency of Human Services Internal Audit Group (AHS-IAG) is a designated centralized reporter of subawards for a Medicaid cluster (ALN 93.775, 93.777, 93.778) that is shared between all AHS departments. To address omissions and timeliness of subawards and subaward modifications reporting to FSRS, IAG conducted additional training tailored to each AHS Department to examine the results of FFATA testing conducted internally and reemphasized the FFATA compliance regulations. This ensured the Internal Audit Group (IAG) is provided with complete, accurate and timely subaward information for reporting in FSRS going forward. The results of the 2023 finding show that the departments understood the training materials and complied with the requirements to report. Although not timely, regarding the reporting in FY2023, the FY2024 should yield timeliness because of the prior year corrective action completion that was closed on 04/11/2023. On at least an annual basis, IAG conducts a review of current federal rules and regulations pertaining to FFATA reporting for FSRS to assure the Agency’s procedures are up to-date. Coincidentally, IAG will also select a random sample of subawards and subawards modifications that meet the required threshold for FFATA reporting to ensure they are reported in FSRS system on a complete, accurate and timely basis. Scheduled Completion Date of Corrective Action Plan: December 31, 2023: Annual review of FFATA rules and regulations including subawards review. Contacts for Corrective Action Plan: Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384906 (2023-029)

Material Weakness 2023

State of Vermont

VT

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking § 200.303

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

View Audit 297960

Finding 384905 (2023-028)

Significant Deficiency 2023

State of Vermont

VT

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

With the 2022-36 Corrective Action Plan, Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax stan...

With the 2022-36 Corrective Action Plan, Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. The State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Deidra Jarvis, DVHA Supervisor of Member and Provider Services deidra.jarvis@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384904 (2023-027)

Significant Deficiency 2023

State of Vermont

VT

Procurement, Suspension & Debarment Eligibility Significant Deficiency § 200.303

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

View Audit 297960

Finding 384903 (2023-026)

Significant Deficiency 2023

State of Vermont

VT

Questioned Costs Eligibility Student Financial Aid § 200.303

DCF has updated the eligibility determination procedure document and referenced checklists to ensure that there are additional reviews of the manual data entry and its processing in the data system (SSMIS). There is a process in place by which any cases where manual data entry causes erroneous IV-E ...

DCF has updated the eligibility determination procedure document and referenced checklists to ensure that there are additional reviews of the manual data entry and its processing in the data system (SSMIS). There is a process in place by which any cases where manual data entry causes erroneous IV-E draws, the Department will make changes in the data system and return IV-E funds erroneously claimed within one quarter of the mistake being identified. Scheduled Completion Date of Corrective Action Plan: January 1, 2024 Contact for Corrective Action Plan: Gillie Hopkins, DCF-FSD Permanency Planning Program Manager gillie.hopkins@vermont.gov Barbara Joyal, DCF-FSD System of Care Unit Director barbara.joyal@vermont.gov Beth Sausville, DCF-FSD System of Care Unit Director beth.sausville@vermont.gov Ed Dwinell, DCF Business Office, Financial Director ed.dwinell@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960 Questioned Costs: $1

Finding 384901 (2023-024)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

View Audit 297960

Finding 384899 (2023-023)

Significant Deficiency 2023

State of Vermont

VT

Cash Management Allowable Costs / Cost Principles Significant Deficiency § 200.303 § 200.514

The Agency of Human Services receives funding under ALN 93.568 and is responsible for reporting the federal interest liability for this program to the Department of Finance and Management. The Agency of Human Services previously relied on the Department of Finance and Management for notification of ...

The Agency of Human Services receives funding under ALN 93.568 and is responsible for reporting the federal interest liability for this program to the Department of Finance and Management. The Agency of Human Services previously relied on the Department of Finance and Management for notification of the annual interest rate. Going forward, the Agency of Human Services will obtain the annual interest rate directly from the CMIA website: Cash Management Improvement Act - Annual Interest Rates (treasury.gov). The Department of Finance and Management will also verify the Agency of Human Services’ submission prior to submitting the CMIA Annual Report to the US Department of the Treasury. Position Responsible for Implementation of Corrective Action Candace Elmquist Financial Director Candace.Elmquist@vermont.gov Peter Moino Director of Internal Audit Peter.Moino@vermont.gov Date of Implementation of Corrective Action: Completed: 2/6/2024

View Audit 297960

Finding 384895 (2023-021)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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

View Audit 297960

Finding 384883 (2023-019)

Material Weakness 2023

State of Vermont

VT

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking § 200.303

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

View Audit 297960

Finding 384877 (2023-018)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

View Audit 297960

Finding 384875 (2023-016)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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

View Audit 297960

Finding 384874 (2023-015)

Significant Deficiency 2023

State of Vermont

VT

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

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include th...

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include the following key points. 1. Verity the entity on the backup. 2. The period of reimbursement matches the reimbursement request period. 3. The amount on the backup must be the same and cannot be higher (or lower) than the request. 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: 7/01/2024

View Audit 297960

Finding 384866 (2023-013)

Significant Deficiency 2023

State of Vermont

VT

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

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include th...

AOE will do review training to ensure all positions processing reimbursement requests fully understand what is required for backup on payment requests. This training will be conducted jointly by the business office and our compliance team and will be completed by the end of FY24 and will include the following key points. 1. Verity the entity on the backup. 2. The period of reimbursement matches the reimbursement request period. 3. The amount on the backup must be the same and cannot be higher (or lower) than the request. 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: 7/01/2024

View Audit 297960

Finding 384858 (2023-009)

Material Weakness 2023

State of Vermont

VT

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness § 200.303

The reporting portal of the U.S. Treasury changes on an almost quarterly basis. These changes include new data requirements, added/changed functionality, and new data verification mechanisms. The incredibly small group of dedicated reporters for the Agency does their best to ensure that every new c...

The reporting portal of the U.S. Treasury changes on an almost quarterly basis. These changes include new data requirements, added/changed functionality, and new data verification mechanisms. The incredibly small group of dedicated reporters for the Agency does their best to ensure that every new change in the portal process is recognized and incorporated into our processes and that the data in the portal matches what we have on file. Regarding the reporting period in question, current period obligations were inadvertently not reported at the individual project level due to an error in an internal data query used to generate the project upload templates used to enter data into the portal. The error went unnoticed by Agency staff partially because verification of cumulative obligations and total current period obligations, which is automatically verified in the portal and double checked by Agency staff, was successful which suggested there were no issues with the uploaded data. After researching the issue, Agency staff discovered that the data provided at the project level is not used in any auto calculations in the portal and there are no verification mechanisms in place within the portal to ensure it is accurate. Moving forward, the Agency will initiate a new process. A primary review of the templates will be conducted by an individual other than the individual that has prepared the templates before uploading. Additionally, a review of the portal data by a multi-person team will be completed before the portal data is certified. Scheduled Completion Date of Corrective Action Plan: Expected: April, 2024: New processes integrated into FY24 Q3 Reporting Cycle Contacts for Corrective Action Plan: Douglas Farnham Chief Recovery Officer, Vermont State Recovery Office Douglas.Farnham@vermont.gov (802) 585-8119 Ethan Hurley Director of Finance & Operations, Vermont State Recovery Office Ethan.Hurley@vermont.gov (802) 461-5317

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