Corrective Action Plans

2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team has restructured with new leadership and added all new staff. RFA will train new staff, develop and update policies and procedures, and automate processes within ERP systems, as appropriate. RFA is creating current and updated SOPS for each task and making sure the current staff is learning processes the correct way; this includes reconciliation and recording in the correct period. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya Cardwell. Planned completion date for corrective action plan: December 2026

Finding Number: 2024‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Jeannie Raphaelito, Human Resources Technician; Donna Manuelito, Principal Anticipated Completion Date: July 2025 Planned Corrective Action: The School will conduct background investigations as soon as consent is signed by applicant or employee. Prioritization of background completion will be done in accordance with personnel policies and procedures. Repeat Finding due to school board vacating the Human Resources position. The School Board did reconsider dual title of Business Manager/Human Resources and removed the Human Resource Manager duties from Business Manager position description. This change happened before hiring for the vacated Human Recourse position; therefore, all HR duties and responsibilities were not met.

Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Portland is committed to an environment of continuous improvement. Further training shall be provided to Program Managers regarding the organizations’ documented internal controls and the importance of adhering to the established approval process. Urban League has currently hired a seasoned Controller and is in the process of hiring an experienced Accounting Manager. Tracking expiring grants more thoroughly and having further reviews in place to assure transactions are recorded within the grant’s agreed upon period of performance shall provide confidence expenses are recorded properly. Anticipated Completion Date: 05/01/2024

2024-003 H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendations. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed, will reduce the time between placement of order and payment of the invoice. Additionally, management will develop a federal grant policy that covers all requirements for compliance and internal controls for federal grants. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

2024-001: Financial Reporting Management agrees with the finding and has taken immediate steps to address the issue and ensure timely submissions. Grand Street Settlement and BTQ Financial, Inc. will jointly oversee and ensure the timely submission of all progress reports. All agreements will be reviewed in detail to fully understand compliance and reporting requirements, ensuring that all conditions are met, and submissions are made on time. A detailed timeline will be established for each reporting period, with regular check-ins to ensure that progress reports are completed and submitted on schedule. All deadlines will be closely monitored to prevent any future delays. Status of Finding: Management is expected to resolve the finding during fiscal year 2025 and will continue to work on resolving the finding. Managements Response: Management agrees with the finding. The issue will be corrected and resolved by the Grand Street Settlement Director of Administration, Program Director, and BTQ Financial during the fiscal year 2025.

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled “Noncompliance with Period of Performance Requirements." Management Response: The University concurs with the audit finding. Expense Posting Delay ($28,833): This salary charge reflects work performed within the approved award period. The delay occurred because the Personnel Action Form was received after the June payroll run, resulting in disbursements in July and August. Although the work was completed on time, the payroll posting did not align with the period of performance requirements. We are reviewing our processes to ensure all required documentation is received and processed promptly. Liquidation of Obligations ($34,957): The University failed to liquidate obligations totaling $34,957 within 120 days following the period of performance. This shortfall is due to staffing challenges in the Sponsored Programs Finance Administration and Compliance (SPFAC) Department. The University is actively exploring strategies to attract and retain qualified grant accountants to improve timely fund closeouts. Additional Mitigation Measures 1. Engaging External Consultants: o The University will engage an outside consultant to assess the university's research and administration structure, identifying opportunities to enhance processes and ensure compliance. o The University is retaining interim professional staffing to assist with invoicing and pre-audit review and to provide functional and technical expertise. 2. Deployment of an Electronic Research Administration System (eRA) o The University has begun identifying and implementing an electronic research administration system to transform grant management by offering a centralized platform that automates the entire lifecycle from proposal to closeout, minimizing manual errors while ensuring policy compliance and providing clear portfolio visibility through comprehensive reporting capabilities. The SPFAC Director will oversee the implementation of these corrective actions.

Dear Mr. Waguespack, Thank you for the opportunity to respond to your office’s findings related to the Special Tests and Provisions Requirements. LSU Health Sciences Center Shreveport (LSUHSC-S) has reviewed the issues identified by your staff. We concur with your recommendations for addressing the finding and provide the following response and corrective action plan. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests & Provisions requirements. Response and Corrective Action Plan: LSUHSC-S is continuing to strengthen the management, internal controls, and efficiency of the sponsored programs management. In the Fall of 2024 LSUHSC-S began a re-organization of Research Administration, including sponsored programs management. The historical organizational structure supported an office of grants administration (pre-award) that functioned separately from the grants accounting (post-award) functions. This structure created a disconnect between the two functions, caused gaps in the services provided to faculty, and left some responsibilities unattended. The recent re-organization combined Pre-Award Administration and Post-Award Administration into one office, The Office of Sponsored Programs. This team is supervised by the Executive Director for Sponsored Programs and operates under the direction of the Chief Financial Officer and Vice Chancellor for Research Administration. As part of the overall re-organization and improvement of services, several processes are under revision. Time and Effort Reporting: Time and Effort Certification (T&E Certification) transitioned to an electronic process in January 2025. The electronic process is designed to ensure a more efficient certification process and one that is easily documented. T&E Certification is performed on a bi-annual basis. In addition to the certification process, comprehensive training will be provided for Business Managers, Principal Investigators, and other designated departmental staff on an annual and PRN basis. A Post-Award Monitoring process is currently being established for all sponsored programs. Quarterly meetings will be held with Principal Investigators (PIs), Business Managers, and other designated department staff to review documentation of monthly grant account reconciliations, assist and review payroll cost transfers, changes in key personnel, etc. These regular meetings will serve as a checkpoint to review all personnel, payroll and effort supported by grant accounts. PIs and/or departmental staff are expected to perform monthly reconciliation of grant accounts, and the Post-Award Monitoring Meetings will serve as the platform for reviewing the documentation. Post-Award Monitoring Meetings: All agenda items reviewed and discussed in the Post-Award Monitoring Meetings will be documented and follow-up on a quarterly basis or more frequently as needed. Changes in Key Personnel: All changes in key personnel that require federal agency approval must have documented approval from the federal agency prior to the change in personnel occurring. Federal agency approval for key personnel changes must be received prior to the submission of a PER for any employee changes. Changes in key personnel will be reviewed during the Post-Award Monitoring meetings. Training: LSUHSC-S continues to improve training materials covering federal, state, and institutional requirements. Additional training will be provided covering the responsibilities of sponsored programs management and who owns each responsibility. The annual training required for all employees involved in research activities will include Time & Effort, cost allocations, changes in key personnel and other related topics. Continuing education will be provided for Principal Investigators, Business Managers, and designated departmental employees. One-on-One departmental training will also be provided on an as needed basis. The Post-Award Monitoring meetings with department staff will serve as an additional opportunity for training. Name of Contacts Responsible for Action Plan: Ramey Benfield, Chief Financial Officer & Vice Chancellor for Research Administration Ashley Krukowski, Executive Director for Sponsored Programs Valarie White, Director for Pre-Award Administration in Sponsored Programs Tracy Calvert, Director for Post-Award Administration in Sponsored Programs Anticipated Completion Date: June 30, 2025 If you have questions or require additional information, please contact me at 318-675-6327 or via email at ramey.benfield@lsuhs.edu

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) Period of Performance Summary of Finding: During fiscal year 2023-24, the School Corporation was part of Cooperative School Services, which managed special education programs and federal funds for member schools. Funds for Special Education needed to be obligated by September 30, 2023. Three exceptions occurred with late obligations. It is recommended that the School Corporation create internal controls to prevent late costs and ensure compliance. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will work with Cooperative School Services to ensure that funds are obligated prior to the grant obligation deadline. Anticipated Completion Date: June 1, 2025

Management agrees with this finding. Triad Adult and Pediatric Medicine has updated its Grant Policy and Procedure to address how the organization can reasonably ensure that costs claimed against future federal awards will be allowable federal costs that are incurred within the approved period of performance and meet federal cost principles. This action was the responsibility of the Chief Financial Officer and has been completed. The questioned costs have been repaid and the matter is considered closed.

Finding No. 2024-002: Period of Performance (Significant Deficiency – Federal Awards) Federal Award: 14.218 - CDBG – Entitlement Grants Cluster Audit Recommendation: We recommend the City adhere to the workout plan submitted to HUD to comply with the CDBG timely expenditure requirements. Administration’s Comments: The City will adhere to procedures to comply with the CDBG timeliness standard specified. Anticipated Completion Date: June 30, 2025 Contact Person(s): Holly Kawano, Department of Budget and Fiscal Services, Federal Grants Coordinator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We are actively addressing this issue while highlighting the Division of Vocational Rehabilitation’s (“DVR’s”) high compliance rate of 98.3 percent. The Vocational Rehabilitation Specialist (“VRS”) and the Vocational Rehabilitation Manager have been thoroughly informed about the correct data entries required for Service E (work experiences while in Service status). It’s essential to note that “competitive integrated employment” must not be selected for Service E status. Instead, staff should choose alternatives such as “internships, whether paid or unpaid,” or “transitional employment” to ensure accurate data recording and prevent the inclusion of data element 350. Additionally, “competitive integrated employment” requires the client to be actively employed in alignment with their employment goal outlined in their Individualized Plan for Employment with a stable employment value date entered in the employment record. To assist our staff in this process, the Aware-System Bulletin will include a clear reminder to verify both the employment status and the stable employment value date for each case. Instructions for using the managed layout edit checker will also be provided, equipping staff with the necessary tools to identify errors and make corrections independently. The VRS will ensure that the Service E or Employed status aligns appropriately with the appropriate employment categories. This corrective action reinforces best practices and significantly improves staff compliance with the accuracy of our data from DVR’s case management system. Completion Date: On going monitoring and training as needed. Responding Official(s): Lea Dias, Vocational Rehabilitation Administrator and R. Pascual-Kestner, Vocational Rehabilitation Assistant Administrator

Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are met. Multiple notifications are provided to these parties in advance of due dates. Contact Person Responsible for Corrective Action: Brian Barrett, Hudu Ahmed and Louisa Dallett Completion Date: March 1, 2025

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

– 84.425F Finding: Two errors were noted related to period of performance: 1) the lost revenue calculation was completed in October 2023, which was after the June 30, 2023 period of performance date; and 2) the District also spent money on expenses for the program in November 2023 and January 2024, which was after the 120-day liquidation period. Corrective Action Taken or Planned: The School will create and maintain a funding schedule according to the grant agreements. The schedule will be reviewed by various finance staff members for timing of grant reimbursements and deadlines. Contact person: Mike Stephens, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.

2024-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: Following consultation with the National Student Clearinghouse (NSC), guidelines were provided for handling various status change scenarios. These guidelines will enhance the accuracy of enrollment status change reporting, particularly for students with changes occurring before or after the subsequent enrollment file submission. Status changes are now being reported to the NSLDS in a timely and accurate manner, in accordance with the NSC guidelines. The University has also implemented a reporting timeline and review protocols to ensure status changes are reported to the U.S. Department of Education’s National Student Loan Data System (NSLDS) in a timely manner. Additionally, the University will collaborate with its Information Technology Services and representatives from the NSC and NSLDS to verify the accuracy of the file layouts and the data flow of the information provided. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Partially implemented. The University is collaborating with its Information Technology Services and representatives from the NSC and NSLDS on accurate reporting of the program start date, which is expected to be completed during Fiscal Year 2026.

Department of Justice Federal Financial Assistance Listing #16.582 Activities Allowed and Allowable Costs, Period of Performance Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over activities allowed and allowable costs and period of performance identified five employee timecards that were not reviewed and approved by an individual other than the employee. Responsible Individuals: Jamie Schaefer, John Neth Corrective Action Plan: The organization will review and strengthened the controls surrounding activities allowed and allowable costs as well as period of performance compliance. Avera Health has updated its enterprise resource planning system to Workday, which utilizes an effort certification system. Within the effort certification system, Individuals will self-report/certify their time, the certification will then route to the specific grant management staff instead of the cost center supervisor. Anticipated Completion Date: June 30, 2025

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Documentation of review for adjustments/corrections, including the period of performance, will be maintained for auditor review. Anticipated Completion Date: June 15, 2025

Condition: Of the 40 samples included in our sample selected for testing in the Research and Development Cluster (R&D), the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Planned Corrective Action: The university has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period. Contact person responsible for corrective action: Associate Controller, Brenda Lindberg Anticipated Completion Date: The new grants module, which includes grant billing and award calendar schedule became operational at July 1, 2024.

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

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

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