Corrective Action Plans

Finding 537424 (2024-006)

Material Weakness 2024

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S42...

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass‐Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

View Audit 348618

Finding 537423 (2024-005)

Material Weakness 2024

Blackford County Schools

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and...

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and Year (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: Agree Description of Corrective Action Plan: This was a singular occurrence where the rate for a remedial program was not approved by the BCS school board, and where the payments did not tie back to an allowable cost. This program and fund are no longer active. Anticipated Completion Date: Completed

View Audit 348618 Questioned Costs: $1

Finding 537413 (2024-028)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEM...

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEMA-4474-DR-VT (2020), FEMA-4532-DR-VT (2020), FEMA-4621-DR-VT (2021), FEMA-4695-DR-VT (2023), FEMA-4720-DR-VT (2023) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should continue to improve its procedures and internal controls to ensure that all required subawards and subaward modifications are reported accurately and timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Public Safety will continue implementation of its corrective action plan from the prior year. A new procedure will be developed for a periodic review of FFATA entries to add a control step ensuring that all FFATA entries are timely and accurate. A training will also be delivered to Public Assistance staff to ensure that the FFATA entry process is understood in both FSRS and SAM.gov. These corrective actions will be completed by April 4th, 2025 Scheduled Completion Date of Corrective Action Plan: April 4, 2025 Contacts for Corrective Action Plan: Richard Hallenbeck, Director of Administration/Finance richard.hallenbeck@vermont.gov

View Audit 348596

Finding 537400 (2024-023)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-023 Prior Year Finding: 2023-030; 2022-038; 2021-026 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/...

Reference Number: 2024-023 Prior Year Finding: 2023-030; 2022-038; 2021-026 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023) 2405VT5MAP (10/1/2023 – 9/30/2024) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency complete implementation of its prior year CAP to ensure that all required subawards and subaward modifications are reported timely to FSRS in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: 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 context of the 2024 finding indicates that the departments understood the training materials and complied with the requirements to report. 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: March 31, 2025: 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 348596

Finding 537387 (2024-021)

Significant Deficiency 2024

State of Vermont

VT

Eligibility Student Financial Aid Subrecipient Monitoring § 200.303

Reference Number: 2024-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/202...

Reference Number: 2024-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it verifies U.S. citizenship for all participants and confirm that only eligible participants receive benefits under the program. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: This finding has been corrected as of January 2024 dating back to October 2023. The State is no longer pooling funding sources which means that we can identify cases by their true funding source. This means that only true CCDF cases will be audited going forward and family service cases (protective service) no longer follow CCDF rules including citizenship and identity. Scheduled Completion Date of Corrective Action Plan: December 31, 2024 Contacts for Corrective Action Plan: Karolyn Long, Operations Director karolyn.long@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537386 (2024-020)

Material Weakness 2024

State of Vermont

VT

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Reference Number: 2024-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/202...

Reference Number: 2024-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Special Tests and Provisions – Health and Safety Requirements Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance training monitoring procedures and controls to ensure that all child care providers complete required health and safety training. We further recommend that the Agency update its training content to ensure that it includes all required elements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Department for Children and Families-Child Development Division (DCF-CDD) licensing unit is in the process of rule revisions which will include all the required health and safety topics that must be covered within the first three months of employment. DCF-CDD licensing unit will be updating our monitoring checklists to ensure we are regulating to the federal standard. DCF-CDD licensing unit will conduct staff training that review the results of the SFY 2024 Single Audit and establish clear procedures for licensing staff to follow when monitoring licensed providers and their staff for ongoing professional development requirements. Scheduled Completion Date of Corrective Action Plan: DCF-CDD is currently in the rule revision process and have a goal to shepherd the rules through promulgation by December 31, 2025. DCF-CDD will update our monitoring checklists to align with the rule revision which will include a complete pre-service orientation training list that aligns with the federal standard. This will be completed by December 31, 2025. DCF-CDD will review the results of the SFY 2024 Single Audit with the licensing team on January 21, 2025. Licensing supervisors will begin reviewing annual site visit reports for the licensors they supervise to ensure CDD is monitoring for the required ongoing professional development trainings required beginning immediately. Contacts for Corrective Action Plan: Beth Maurer, Director of Child Care Licensing elizabeth.maurer@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537378 (2024-018)

Material Weakness 2024

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Reference Number: 2024-018 Prior Year Finding: 2023-024 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Hea...

Reference Number: 2024-018 Prior Year Finding: 2023-024 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Award Number and Year: NH75OT000034 (6/1/2021 – 5/31/2026) 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 complete implementation of its prior year CAP 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 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 SFY24 Single Audit pre-dated the implementation of the Health Department’s original corrective action plan. Scheduled Completion Date of Corrective Action Plan: February 1, 2023 Contacts for Corrective Action Plan: Lillian Smith, Financial Administrator lillian.smith@vermont.gov Jessica Brown, Financial Manager jessica.brown@vermont.gov Megan Hoke, Financial Director megan.hoke@vermont.gov Peter Moino, Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537373 (2024-016)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-016 Prior Year Finding: 2023-018; 2022-029; 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Governor’s Emergency Education Relief Fund COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) C...

Reference Number: 2024-016 Prior Year Finding: 2023-018; 2022-029; 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Governor’s Emergency Education Relief Fund COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021 – Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) COVID-19 - American Rescue Plan – Elementary and Secondary School Emergency Relief –Homeless Children and Youth Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U, 84.425W Award Number and Year: S425C210009 (1/8/2021 – 9/30/2022) S425D210011 (1/5/2021 – 9/30/2022) S425R210033 (2/23/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) S425W210047 (4/23/2021 – 9/30/2023) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior audit. It should review and enhance internal controls and procedures to ensure that all required subawards and subaward amendments are reported timely and accurately to FSRS no later than the end of the month following the month of issuance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency implemented a reconciliation process in March of 2023 that allows us to ensure our grant ledgers agree with what is entered into FFATA. The Agency will increase the number of reconciliations per year to quarterly. The Agency continues to work toward our preferred solution to address the accuracy and timeliness of our entries into the FFATA system by creating an upload file of the data from our grants management system. Scheduled Completion Date of Corrective Action Plan: July 1, 2025 Position Responsible for Implementation of Corrective Action Sean Cousino, Interim CFO sean.couisno@vermont.gov

View Audit 348596

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 537366 (2024-011)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting § 200.208 § 200.303 § 200.332 § 200.425 § 200.513

Reference Number: 2024-011 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: Subrecipien...

Reference Number: 2024-011 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: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Missing Federal Award Date: The Contract Administration, Grants Unit addressed the deficiency of missing federal award dates during the FY23 State Single Audit (in effect as of 1/12/2024). As part of the updated award execution process, the Grants Unit now verifies that all awards include the federal award date and applicable FAIN number. Awards executed prior to the implementation of this process are being updated during amendments to ensure compliance. Subrecipient Monitoring: The root cause of the subrecipient monitoring deficiency was staffing shortages, which affected the Agency of Transportations (AOT) ability to meet monitoring requirements on time. The AOT monitoring requirements have been transitioned from the Audit Bureau to the Contract Administration, Grants Unit. The Grants Unit has already identified and will prioritize Subrecipients based on the last date monitored. Workflow modifications to include efficiencies are also in progress. These efficiencies will help with timeliness. The revisions to the monitoring activities will be in the VTrans Granting Plan effective July 1, 2025. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of July 1, 2025. Contacts for Corrective Action Plan: Tricia Scribner, Administrative Services Manager III tricia.scribner@vermont.gov

View Audit 348596

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 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

View Audit 348596

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

View Audit 348596

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 537307 (2024-002)

Significant Deficiency 2024

Municipality of Moca

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.328

Finding 2024-002: Compliance requirement: Reporting-Coronavirus State and Local Fiscal Recovery Reportable Condition: See Condition 2024-002 Recommendation ...

Finding 2024-002: Compliance requirement: Reporting-Coronavirus State and Local Fiscal Recovery Reportable Condition: See Condition 2024-002 Recommendation The Municipality should maintain the schedule of the due dates or the reuired rports of each federal program to comply with the required submissions to the federal awarding agencies. Also, they had to submi the quaterly report to comply with the requiremnts. Action Taken Due to the shift from annual to quaterly reporting, the Municipality initially missed a quaterly report deadline because of unfamiliarity with the new schedule. however, since then , we have consistently met all the subsequent quaterly deadlines. we will continue to carefully monitor and verifiy all reporting deadlines to guarantee accurate and timely submissions moving foward.

View Audit 348562

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 537283 (2024-001)

Significant Deficiency 2024

United Way of Monterey County

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In the current fiscal year, all part...

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In the current fiscal year, all partnering agencies were required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. In response to the compliance finding for our June 30,2024 Single Audit, United Way Monterey County will implement a year end ERAP closeout with all partners who received direct financial assistance. There will be monitoring visits done by the Vice President of Community Investments. Any record of noncompliance will be documented accordingly. The UWMC staff member overseeing these monitoring visits for us is: Josh Madfis VP, Community Investments Josh.madfis@unitedwaymcca.org (831) 372-8026

View Audit 348524

Finding 537276 (2024-002)

Material Weakness 2024

Putnam County District School Board

FL

Questioned Costs Subrecipient Monitoring

PLANNED CORRECTIVE ACTION - Although we disagree with the finding, moving forward, and in accordance with your recommendation, the Putnam County School District will review procedures that ensure compliance and make any necessary changes where needed. The district believes that the board and state...

PLANNED CORRECTIVE ACTION - Although we disagree with the finding, moving forward, and in accordance with your recommendation, the Putnam County School District will review procedures that ensure compliance and make any necessary changes where needed. The district believes that the board and state approved additional compensation followed the budget narrative including all amendments, specifically amendments #8 and #11 in our federal project (#540-1211A-2C001). All payments were done via an internal procedure through MOUs that are signed between the Putnam Federation of Teachers/United (PFT/United) and the School Board. The MOUs were signed on September 27, 2023, November 29, 2023, February 26, 2024, and April 3, 2024 with payments being disbursed within 30 days after each. In fiscal year 2023-24, there were four iterations of payments made which reflected budget narratives from the original award letter, amendment 8 and amendment 11. The payments were processed using an internal procedure that ensures an agreement between the District and the PFT/United. These signed agreements align with the expectations of the Code of Federal Regulations in Title 2, Section 200.430(f) where employee compensation must be according to an agreement entered into before the services were rendered or according to an established plan followed by the subrecipient so consistently as to imply, in effect, an agreement to make such payment. In regards to doubling the amounts established in the plan, the PCSD believes amendment #8 and the accompanying email chain with the amendment provided for two additional iterations of the compensation and thus put us within the correct number of compensation payments to PCSD employees throughout the life of the project. ANTICIPATED COMPLETION DATE - None RESPONSIBLE CONTACT PERSON - Jonathan L. Odom, MBA, Chief Finance Officer; Laura France, Assistant Superintendent - Curriculum and Instruction; Ashley McCool, Executive Director of Federal Programs

View Audit 348511 Questioned Costs: $1

Finding 537253 (2024-002)

Significant Deficiency 2024

Youth Shelters and Family Services, Inc.

NM

Reporting Subrecipient Monitoring Significant Deficiency § 200.510

Views Of Responsible Officials and Corrective Action Plan Response: Youth Shelters and Family Services, Inc. (YSFS) acknowledges the finding and agrees that improvements are needed in preparing the Schedule of Expenditures of Federal Awards (SEFA). YSFS is committed to ensuring compliance with 2 C...

Views Of Responsible Officials and Corrective Action Plan Response: Youth Shelters and Family Services, Inc. (YSFS) acknowledges the finding and agrees that improvements are needed in preparing the Schedule of Expenditures of Federal Awards (SEFA). YSFS is committed to ensuring compliance with 2 CFR 200.510(b) and will take the necessary steps to enhance the accuracy and timeliness of SEFA preparation. Corrective Action Plan: To address the identified deficiencies, YSFS will develop processes to aid in the implementation of the following corrective actions: 1. Establish a Formal SEFA Preparation Process: • Develop and implement a standardized SEFA preparation procedure, including all required elements (a federal portion of expenditures, grant name, grantor name, Assistance Listing number, and pass-through entity information). • Assign clear responsibilities for SEFA preparation and review to designated finance personnel. • SEFA will be prepared quarterly, rather than waiting until year-end, to allow for ongoing review and corrections. 2. Improve Internal Controls Over SEFA Preparation: • Implement a reconciliation process to compare SEFA expenditures with the federal revenues and expenditures. • Review and update QuickBooks job categories regularly to ensure proper coding of federal expenditures. • Establish a dual-review process where a second finance team member or external consultant reviews SEFA for accuracy before submission. 3. Training and Capacity Building: • Provide training to finance staff on Uniform Guidance requirements for SEFA preparation. • Ensure staff are familiar with federal grant compliance requirements and reporting obligations. 4. Enhance Monitoring and Accountability: • Set internal deadlines for SEFA preparation to prevent delays. • Conduct periodic internal reviews of federal grant expenditures to ensure compliance and accuracy. • Management oversight of SEFA preparation is required to ensure completeness and correctness. Finding resolved timeline: YSFS aims to develop a process to implement these corrective actions and have an accurate, timely SEFA process by June 30, 2025, to ensure compliance with federal regulations in the upcoming fiscal year. Designation of employee position responsible for meeting this deadline: Heather Hoffman, Julie Weigand, and an external consultant will oversee and ensure this corrective action plan's development and successful implementation.

View Audit 348481

Finding 537246 (2024-003)

Material Weakness 2024

City of Fairfield

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303 § 200.318 § 200.327

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to ...

Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials: We concur. Corrective Action Plan: The City’s grant policy requires compliance with grant guidelines, referencing CFR 200.303(a) and directing staff to the SAM.gov website and CFR 200 guidelines. However, the department that applied for and accepted the grant failed to include CFR 200 Appendix II in the Professional Services Agreement and did not document the review of contractor status on SAM.gov. To address this, the City will provide targeted training for departments and staff involved in grants, focusing on compliance with grant policies, special provisions, and proper documentation of actions. Responsible Individual(s): Anna Guiles, Assistant Community Development Director Anticipated Completion Date: To be completed by 3/31/2025

View Audit 348452

Finding 537239 (2024-001)

Material Weakness 2024

Cape Girardeau County Public Health Center

MO

Procurement, Suspension & Debarment Subrecipient Monitoring

Name of Contact Person: Autumn Grim, Director. Recommendation: We recommend the Center verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep all supporting documen...

Name of Contact Person: Autumn Grim, Director. Recommendation: We recommend the Center verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000 and to keep all supporting documentation of the verification of the vendor's status. Corrective Action: We will verify all vendors' status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000. Proposed Completion Date: Immediately.

View Audit 348442

Finding 537237 (2024-002)

Material Weakness 2024

Learningworks

ME

Subrecipient Monitoring Material Weakness

LearningWorks has been working with an external accounting consultant since July of 2024. This seasoned CPA with valuable experience in nonprofit financial management has offered counsel and support with various issues. Moving forward, her support will include developing and executing a monthly revi...

LearningWorks has been working with an external accounting consultant since July of 2024. This seasoned CPA with valuable experience in nonprofit financial management has offered counsel and support with various issues. Moving forward, her support will include developing and executing a monthly review process in order to meet industry and Uniform Guidance standards. Additionally, we are willing to institute further recommended practices that will remediate this finding.

View Audit 348423

Finding 537232 (2024-001)

Significant Deficiency 2024

New Jersey City University Foundation, Inc, and Affiliate

NJ

Subrecipient Monitoring

Appendix B – Corrective Action Plan To: PKF O’Connor Davies, LLP, U.S. Department of Education From: Brian Kirkpatrick, Vice President of Administration and Finance Date: March XX, 2025 RE: New Jersey City University Foundation, Inc. and Affiliate Corrective Action Plan 2024-001 – Grant Agreem...

Appendix B – Corrective Action Plan To: PKF O’Connor Davies, LLP, U.S. Department of Education From: Brian Kirkpatrick, Vice President of Administration and Finance Date: March XX, 2025 RE: New Jersey City University Foundation, Inc. and Affiliate Corrective Action Plan 2024-001 – Grant Agreements Federal Assistance Listing Number: 84.031 Name of Program or Cluster: 84.031 Higher Education Institutional Aid: Opening the Gate: Improving Math Success for STEM Careers (Endowment Corpus)--84.031C, Closing the Completion Gap for HIS Community-College Graduate (Endowment Corpus)--84.031C, Picking Up the Pace: Ensuring Hispanic Degree Completion (Endowment Corpus)--84.031S, Proyecto Stem: Evidence-Based Approaches to STEM Enrollment (Endowment Corpus)--84.031C Agency: U.S. Department of Education Name of Passed-Through Entity: New Jersey City University (the “University”) Criteria: Per federal regulation CFR 624.41 paragraph (a) (1), an institution that the Secretary selects to receive an endowment challenge grant shall enter into an agreement with the Secretary to administer the endowment challenge grant. Condition: New Jersey City University Foundation, Inc. and Affiliate, (the “Organization”), was unable to present a formalized subrecipient agreement entered into at the inception of the endowment between the University and the Organization. Cause: Programs were initiated between the years 2013 through 2018 and were audited as part of the University’s audits in accordance with Uniform Guidance. The Organization’s staff have been unable to locate the subrecipient agreement which were entered into several years ago. Effect: Noncompliance with federal regulation over grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes, see finding 2023-001. Recommendation: The Organization should maintain all records for Endowment Challenge Grants in accordance with federal regulation over grant compliance requirements. Views of Responsible Official: Although the Organization had provided a memorandum of understanding to the auditors which provided details of the endowment challenge grants, the Organization will coordinate with the University to establish a formal subrecipient agreement that is approved by each of their respective boards.

View Audit 348416

Finding 532016 (2024-104)

Significant Deficiency 2024

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Corrective Action Plan: The Red Hat Enterprise Linux (RHEL) Extended Life Cycle Support license for UTMB’s 51 PeopleSoft RHEL7 servers was received on Friday 10/4/2024 for service dates through 6/30/2025. Furthermore, these servers will be updated to RHEL9 in the first half of 2025. Implementati...

Corrective Action Plan: The Red Hat Enterprise Linux (RHEL) Extended Life Cycle Support license for UTMB’s 51 PeopleSoft RHEL7 servers was received on Friday 10/4/2024 for service dates through 6/30/2025. Furthermore, these servers will be updated to RHEL9 in the first half of 2025. Implementation Date: October 4, 2024 Responsible Person: Darwin VanDyke, IT Services – Director of Administrative & Research Information Systems

View Audit 348386

Finding 530405 (2024-026)

Significant Deficiency 2024

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

Corrective action plan: The Purchasing and Historically Underutilized Business Services (PHS) unit within PCS will provide additional mandatory training to staff responsible for vendor compliance checks. PHS will also revise the current Vendor Compliance Checks Procedure to include the evidence re...

Corrective action plan: The Purchasing and Historically Underutilized Business Services (PHS) unit within PCS will provide additional mandatory training to staff responsible for vendor compliance checks. PHS will also revise the current Vendor Compliance Checks Procedure to include the evidence required to document compliance, including the run date. Furthermore, PHS management will establish a process for reviewing and approving the Form 1400 Procurement Checklist, regardless of the monetary value, to guarantee that vendor compliance checks are executed accurately and timely and in advance of covered transactions. Implementation dates: March 31, 2025 Responsible persons: Sonya Bebley, Director of Purchasing and Historically Underutilized Business Services, Procurement and Contract Services Department

View Audit 348386

Corrective Action Plans

Filters