Corrective Action Plans

Finding 1182889 (2025-018)

Material Weakness 2025

SC

Cash Management Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are ...

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: Grant draws will be created by one Budget staff member and reviewed by another Budget staff member. The creation and review process of the draws will be supported by two signatures recorded on the draw form, that of the creator and that of the reviewer. Anticipated completion date: July 1, 2025 the process was put into place. The Budget staff along with the Program staff will be responsible for the corrective action plan. Simon Li 803-898-3443

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Finding 1182888 (2025-017)

Material Weakness 2025

State of South Carolina

SC

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.430

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are ...

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency 2025-017 Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Will have to be ongoing Budget and Program staff will be responsible for the corrective action plan. Simon Li 803-898-3443

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Finding 1182887 (2025-016)

Material Weakness 2025

State of South Carolina

SC

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

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers ...

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: Agency policy was previously amended to ensure adequate internal controls. Additional staff training has been conducted to ensure full understanding of the policy changes to prevent future errors. Anticipated Completion Date: 10/30/2025 Name of the contact person responsible for corrective action: • Lauren Wright at (803) 896-8115

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Finding 1182885 (2025-015)

Material Weakness 2025

State of South Carolina

SC

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers ...

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation 2025-015 State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: Agency policy was previously amended to ensure adequate internal controls. Additional staff training has been conducted to ensure full understanding of the policy changes to prevent future errors. Anticipated Completion Date: 10/30/2025 Name of the contact person responsible for corrective action: • Lauren Wright at (803) 896-8115

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Finding 1182883 (2025-014)

Material Weakness 2025

State of South Carolina

SC

Reporting Subrecipient Monitoring § 200.303

The South Carolina Department on Aging (SCDOA) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consiste...

The South Carolina Department on Aging (SCDOA) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services (HHS) – Administration for Community Living (ACL) 2025-014 Aging Cluster – Assistance Listing No. 93.044, 93.045, and 93.053 Disposition of Audit Finding: The SCDOA concurs with the audit finding. Corrective Action: To prevent future occurrences, the Department will implement the following measures: • A secondary review process has been established requiring supervisory approval before report submission. • Supporting documentation including general ledgers will be cross-referenced prior to finalization and documentation will be saved. Anticipated Completion Date: 12/05/2026 Names of the contact persons responsible for corrective action: • Syeeda Gallman, Finance Director at 1-803-734-9917 • Towanda Prior, Grants Manager at 1-803-734-9950

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Finding 1182878 (2025-013)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency § 200.303

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings ...

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS concurs with the audit finding. Corrective Action: Management hereby proposes the Corrective Action Plan below. The Department will implement a control to ensure that the following Codes of Federal Regulations are being met: 42 CFR 438.602 (e) The state has implemented this requirement into its’ July 1, 2024 through June 30, 2027 contract with the MCOs. While the contract gives the MCOs a three-year period to have this audit completed, SC DHHS will engage each MCO to make a commitment to the date to have this audit completed and submitted. The audits will be submitted to the Director, Medicaid Managed Care Financing with copies to the Bureau Chief of the Bureau of Managed Care, and the Director of Strategic Communications in the Office of Communications and Public Relations. The Director, Medicaid Managed Care Financing will be responsible for tracking the submissions. 42 CFR 438.602 (g) The specific reference to the posting of the results of any audits under paragraph (e) is 42 CFR 438.602 (g)(4). The expected date of submission of the audits required under paragraph (e) will be provided to the Bureau Chief of the Bureau of Managed Care and the Director of Strategic Communications in the Office of Communications and Public Relations. The Director, Medicaid Managed Care Financing will be responsible for tracking the submissions and confirming with the Office of Communications and Public Relations the audits have been posted to the agency’s website. Anticipated Completion Date: June 30, 2026 Name of the contact person responsible for corrective action: • T Clark Phillip at (803) 898-1017

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Finding 1182874 (2025-012)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency § 200.303

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings ...

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS concurs with the audit finding. Corrective Action: In accordance with the current contract with the state survey and certification agency, the South Carolina Department of Public Health (DPH), SCDHHS has implemented the following actions to address the Provider Health and Safety Standards audit finding: • SCDHHS requires DPH to submit a quarterly summary report to SCDHHS which identifies nursing facilities surveyed, and F tags cited, including scope and severity measures. • SCDHHS requires DPH to submit a cumulative end-of-year report confirming that each facility has had a survey within an average interval not to exceed 12 months, and no later than 15 months after the date of the previous survey. • SCDHHS and DPH hold quarterly meetings to review the submitted reports and discuss findings. Meetings were held on 7-25-25 and 10-30-25, and the next meeting is scheduled for 1-15-26. Anticipated Completion Date: Completed Contact persons responsible for corrective action: • Margaret Alewine at (803) 898-0047 • Lisa Ragland at (803) 898-1387

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Finding 1182870 (2025-011)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Special Tests & Provisions Eligibility § 200.303

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings ...

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS management concurs with the audit finding. Corrective Action: Regarding the Provider Enrollment Revalidation finding - One provider whose last enrollment validation date was 5/10/2014. The revalidation date for this provider would have been due by 5/10/2019 which would have been before the start of the Public Health Emergency (PHE). The current Provider Enrollment and Support Functions Team Director was not with SCDHHS at the time of the missed revalidation and we are unable to attest to reasons this provider did not complete revalidation, as required. Anticipated Completion Date: Our post-PHE revalidation restart began in July 2024 and will conclude by the required completion date of February 28, 2027. Once SCDHHS completes our current revalidation schedule, we will resume normal revalidation cadence. Contact persons responsible for corrective action: • Dawn Hunt at (803) 898-1843 • Nick Constantino at (803) 898-2561

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Finding 1182866 (2025-010)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Special Tests & Provisions § 200.303

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings ...

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2025-010 Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS management concurs with the audit finding. Corrective Action: • Regarding the five providers identified as not meeting SCDHHS eligibility requirements, we do not currently have a process, nor a mechanism in place, that allows SCDHHS to monitor the status of provider licenses issued by South Carolina Department of Labor, Licensing and Regulation (SCLLR) or Department of Public Health (DPH). Currently, a provider’s license status is verified during initial enrollment and revalidation. • Recently, SCDHHS completed a project with SCLLR to implement a data exchange allowing access to South Carolina provider licensing information specific to independent pharmacy services. We intend to broaden the scope of our project work with SCLLR to include the license status information for all South Carolina Medicaid providers. While we are actively engaged with SCLLR, we have had initial conversations with DPH and intend to replicate the data exchange process with them for entities licensed by DPH. Anticipated Completion Date: Currently, we do not have a final implementation date but estimate that this could be a six – 12-month timeline following execution of a signed Data Sharing Agreement (DSA). This estimate not only includes work with SCLLR but also required updates to our Medicaid Management Information System (MMIS) and development of associated policies and procedures. Once we have additional information, we will provide an update. Contact persons responsible for corrective action: • Dawn Hunt at (803) 898-1843 • Nick Constantino at (803) 898-2561

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Finding 1182862 (2025-009)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Significant Deficiency § 200.303 § 200.306

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will strengthen controls by enhancing annual trainings to ensure matching requirements are properly tracked, documented, and applied to Federal expenditures as required by the Federal award. Additional notes will be added on the Federal Final Modification forms to address any differences required by the Cooperative Agreement. Anticipated Completion Date: 10/01/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-2031

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Finding 1182861 (2025-008)

Material Weakness 2025

State of South Carolina

SC

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

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. The $2,571 finding was identified by the Agency prior to the audit. The Agency was only able make corrections to the grants which remained open (total of $1,421). The Agency was unable to make corrections for the remaining amount as those grants had been closed. Corrective Action: The Agency relies on SCEIS workflow approvals to verify and approve the period of performance. The Agency currently has three or four levels of approvals (depending on the specific grant) for each Shopping Cart. During this process, the Shopping Carts are reviewed and approved/disapproved by the Cooperative Agreement budget analyst, the Grants Department, the Procurement Department and the Budget & Finance Department. Annual reminders are sent to each Cooperative Agreement and email verification of disbursements are filed. Additional quarterly quality control checks will be added to the process. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-4294

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Finding 1182860 (2025-007)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring Cash Management Allowable Costs / Cost Principles § 200.303

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General non-concurs with the audit finding. 1. The cited Regulation (National Guard Regulation 5-1) was changed from a Regulation to a policy guideline in 2020 by the National Guard Bureau (NGB) Grants and Cooperative Agreements Policy Letter (GCAPL) #20-02 dated 04 February 2020. 2. There is not a risk for interest liability to the State. The basis and thresholds for determining if a program is subject to interest payments is defined in Federal Code 31 CFR Part 205 and Treasury Financial Manual (TFM) 4A-2000, “Overall Disbursing Rules for All Federal Agencies.” In addition, the Cash Management Improvement Act Agreement (CIMA) between The State of South Carolina and The Secretary of the Treasury, United States Department of the Treasury, dated 6/30/2025, does not list the Agency’s Catalogue of Federal Domestic Assistance (CFDA) 12.401 as one of the State’s programs that meets or exceeds the State’s threshold for major Federal assistance programs. 3. The Cash Management testing used a one-to-one analysis based on monthly cash advance requests and monthly expenditures during the same time period. However, the testing, based on NGB Policy 5-1, should be from the date of receipt to the date of disbursement. 4. Lastly, the State of South Carolina’s Department of Administration does not allow submissions for Capital Projects (projects over $250,000) without the funding in possession of the requesting Agency. In addition, neither the Legislative Joint Bond Review Committee (JBRC) nor the State Fiscal Accountability Authority (SFAA) will approve a Capital Project without the Agency having the required funds on-hand. The average Readiness Center Revitalization (Capital Project) can take 2-3 years to complete, and the total funds have to be on-hand to receive approval for the start of the projects. This requires Cooperative Agreement 1001 to advance funding for projects months ahead of the execution of any Purchase Orders. Corrective Action: The Agency will continue to strive to minimize the time elapsed between transfer of funds from the United States Treasury and their disbursement by the State in accordance with the annual Request for Advance Payment Method Authorization signed between the State/Agency and the United States Property and Fiscal Officer (USPFO). Anticipated Completion Date: Current Name of the contact person responsible for corrective action: Anita Ballington at 803-299-4294

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Finding 1182859 (2025-006)

Material Weakness 2025

State of South Carolina

SC

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

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will continue to monitor reports and ensure each Cooperative Agreement adheres to the established Chart of Accounts. The Agency will continue to review purchase submissions in the SCEIS system for adherence to Cooperative Agreement matching requirements. Anticipated Completion Date: 10/01/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-229-4294

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Finding 1182858 (2025-005)

Material Weakness 2025

State of South Carolina

SC

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.430

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency has added additional quality control measures within the approval process, is hiring an additional staff member who will be responsible for auditing personnel actions and personnel files, and has implemented monthly audits in addition to the current standard of annual audits. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Robert Faulk at 803-299-4337

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Finding 1182857 (2025-004)

Material Weakness 2025

State of South Carolina

SC

Subrecipient Monitoring § 200.303

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The SCEMD of the Office of the Adjutant General concurs with the audit finding. Corrective Action: 1. The SCEMD Finance and Administration staff will implement and/or update the succession plan for any role or team member responsible for duties within the FFATA reporting process. 2. SCEMD will continue its monthly review of the South Carolina Recovery Grants (SCRG) platform by the SCEMD Finance and Administration staff to ensure the accuracy of information gathered for FFATA reporting. Where any prior reporting inaccuracies may be identified, FFATA reporting corrections of subrecipient obligations will be made. Anticipated Completion Date: June 30, 2026 Name of the contact person responsible for corrective action: Landry Phillips at LPhillips@emd.sc.gov or 803-737-8559

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Finding 1182855 (2025-003)

Material Weakness 2025

State of South Carolina

SC

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

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2025-003 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The South Carolina Emergency Management Division (SCEMD) of the Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will refine its Public Assistance (PA) Reimbursement Review SOP and related Recovery Grants and Finance staff training to specify a requirement to validate that for projects under PA grants declared in 2018 and before, Direct Administrative Costs (DAC) were expended before the end of the project period of performance. In addition, the Recipient has submitted a time extension for the project period of performance but does not yet have approval from FEMA. Notes: • DAC was an eligible category of costs in PA projects under disaster grants through 2017 and optional for those declared August 1, 2017, through October 04, 2018 (opt-in). • Federal PA policy shifted to a management costs approach for projects under incidents declared on or after October 05, 2018. See attached FEMA Recovery Policy FP 104-11-2. Management costs are eligible for reimbursement up to 180 days after the subrecipient completes its last non-management cost project (p. 5). • Guidance regarding Direct Administrative Costs (see FEMA table attached) indicates that project closeout activities are eligible direct costs,which may have led to the Recipient considering DAC during the closeout period as eligible even when the project period of performance had ended. • The Federal Agency involved, FEMA, closed the project without noting an issue with reimbursement of these expenditures. Anticipated Completion Date: June 30, 2026 2 Name of the contact person responsible for corrective action: • Emily Bentley, SCEMD Chief of Mitigation and Recovery, at (803) 737-8774 • Antonio Johnson, SCEMD Grants and Finance Manager, at (803) 737-8606

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Finding 1182841 (2025-019)

Material Weakness 2025

State of Vermont

VT

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Reference Number: 2025-019 Prior Year Finding: 2024-020 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: 2401VTCCDD (10/1/2023 – 9/30/2026) 2501VTCCDD (10...

Reference Number: 2025-019 Prior Year Finding: 2024-020 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: 2401VTCCDD (10/1/2023 – 9/30/2026) 2501VTCCDD (10/1/2024 – 9/30/2027) 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. The Agency should update its training content to include all required elements and ensure that provider corrective action plans and documentation are properly maintained. Site visit documentation should clearly indicate the results of training requirement monitoring. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: DCF-CDD continues their rule revision process and now has the added support of a project manager and legal counsel. The revision process has been rigorous, and the rules have undergone several drafts. The public has had another opportunity to provide feedback on the latest draft prior to the formal promulgation process. Additionally, CDD received technical assistance from our federal partners to ensure our rule revisions met all CCDF requirements and will continue to refer to this document as we move the rules towards promulgation. The proposed rules will address the findings documented in this audit related to the federal requirement that pre-service orientation includes the required eleven (11) healthy and safety topics which staff will be required to complete, “before being left alone with children, counted in staff to child ratios, or within one (1) month of starting employment, whichever comes first.” DCF-CDD submitted an RFP for a new pre-service orientation training to include all the required health and safety topics that must be covered within the first month of employment. CDD will continue to work with the apparent successful bidder to ensure these modules are available to the field in 2026. DCF-CDD licensing unit will review the results of the single audit with licensing staff and our partners at Northern Lights at CCV (NL). CDD will begin a shift in our site visit preparation process that includes NL providing the division with a complete list of staff who have and who have not completed the required number of annual training hours. CDD licensing will document deficiencies in site visit reports and will require a plan from the providers to come into compliance. Scheduled Completion Date of Corrective Action Plan: DCF-CDD anticipates the licensing rules will be submitted to ICAR on February 20, 2026. This date may need to shift dependent on legal counsel’s final review of the rules and the weeks needed to prepare the documents required at this stage in the promulgation. CDD will be provided with a promulgation timeline which we aim to have completed before the end of 2026. DCF-CDD will seek outside contractual support to develop guidance manuals and training for the field on the rule changes, which includes shifts in required pre-service orientation topics. DCF-CDD pre-service orientation modules are scheduled to be completed within six (6)-nine (9) months from when the contract has been signed between the SOV and the apparent successful bidder. DCF-CDD will implement the site visit preparation practice shift by April-May 2026. This work requires NL staff to shift job responsibilities to accommodate the ongoing training review of the staff for all providers. By January 26, 2026, CDD director of child care licensing will meet with the licensing supervisors to review the results of this audit, review the CAP, and establish a plan for supervisory oversight at it relates to licensors documenting training deficiencies when conducting site visits. By January 27, 2026, CDD director of child care licensing will meet with the licensing unit to review the results of this audit, review the CAP, discuss the shift in site visit preparation practice as we partner with NL who will be reviewing compliance with annual training hours, and discuss the expectations around how deficiencies must be documented in annual site visit reports. Contacts for Corrective Action Plan: Beth Maurer, Director of Child Care Licensing, elizabeth.maurer@vermont.gov Kelly Lyford, Licensing Supervisor, kelly.lyford@vermont.gov Janet McLaughlin, CDD Deputy Commissioner, janet.mclaughlin@vermont.gov Dawn Rouse, Director of Statewide Systems, dawn.rouse@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

View Audit 394235

Finding 1182838 (2025-018)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-018 Prior Year Finding: 2024-018, 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 Hea...

Reference Number: 2025-018 Prior Year Finding: 2024-018, 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 – 3/24/2025) 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 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 FFATA 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 federal reporting system by the last business day of each month. Please note that the scheduled completion date is February 1, 2023 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 SFY25 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, Vermont Department of Health, lillian.smith@vermont.gov Jessica Brown, Financial Manager, Vermont Department of Health, jessica.brown@vermont.gov Megan Hoke, Financial Director, Vermont Department of Health, megan.hoke@vermont.gov Peter Moino, Director of Internal Audit, Vermont Agency of Human Services, peter.moino@vermont.gov

View Audit 394235

Finding 1182832 (2025-013)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-013 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Public Service Department Department of Libraries Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022...

Reference Number: 2025-013 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Public Service Department Department of Libraries Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022 – 12/31/2026) 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 Departments’ review their procedures and internal controls to ensure that subawards are reported timely to SAM.gov in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Departments of Public Service and Libraries, reporting obligations for Federal Funding Accountability and Transparency Act Subaward in SAM.gov will occur on a timely basis. Training for these responsibilities is provided for new employees and ad hoc as the system updates and as SAM.gov releases periodic training. A procedural job aid is in place with detailed instructions for staff who are responsible for the inputs. Compliance will be reported regularly to internal leadership. Written procedures for regular reporting to management about FFATA reporting will be established by the grants and contracts staff. A quarterly meeting will be established between the Departments to discuss and ensure that the reporting obligations have been met. Scheduled Completion Date of Correction Action Plan: Quarterly meeting established. March 31, 2026 Procedural job aid created March 31, 2026 Training provided to employees June 30, 2026 Management monitoring process established June 30, 2026 Contacts for Corrective Action Plan: Brittney Wilson, Deputy Commissioner, brittney.wilson@vermont.gov Tracy Collier, Administrative Services Director, tracy.collier@vermont.gov

View Audit 394235

Finding 1182830 (2025-011)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 ...

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 (4/29/2022 – 4/29/2032) CA0751 (5/1/2023 – 10/1/2028) CA0906 (1/24/2025 – 11/1/2030) 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 review its procedures and internal controls to ensure that subawards are reported timely and accurately to SAM.gov in no later than the end of the month following the month of issuance or modification. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: VTrans will update procedures to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. As part of this update, the Agency will review the current reporting workflow and clearly define roles, responsibilities, and timelines for FFATA reporting. The updated procedure will include guidance for identifying reportable sub-awards, collecting required data elements, and entering information into the appropriate federal reporting system within the required timeframe. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Diane Bigglestone, Financial Director, diane.bigglestone@vermont.gov

View Audit 394235

Finding 1182826 (2025-007)

Material Weakness 2025

State of Vermont

VT

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

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 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: 25A55UI000119 (10/1/2024 – 12/31/2027)...

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 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: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance 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 and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182824 (2025-005)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) 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 review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov

View Audit 394235

Finding 1182821 (2025-003)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-003 Prior Year Finding: 2024-003 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: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...

Reference Number: 2025-003 Prior Year Finding: 2024-003 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: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), 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 year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov 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: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov

View Audit 394235

Finding 1182820 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

View Audit 394233

Finding 1182803 (2025-003)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance,...

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Rogers Senior has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Corrective Action Plans

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