Corrective Action Plans

Finding 385094 (2023-007)

None 2023

Blackburn University Dba Blackburn College

IL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

We’ve updated processes to include documentation of risks associated with protecting customer data. Risk assessment documents and methodologies will be reviewed and updated in consultation with the Vice-President of Administration & Finance and the Director of Technology Services.

View Audit 298219

Finding 385080 (2022-002)

Material Weakness 2023

Cascade Community Healthcare

WA

Subrecipient Monitoring Reporting

We agree with the finding, conclusion, and recommendation. Implementing the quality control monitoring is an improvement opportunity for the Organization. We will implement the quality control monitoring by April 30, 2024.

View Audit 298189

Finding 385079 (2023-001)

Significant Deficiency 2023

Chicanos Por La Causa, Inc. and Subsidiaries and Affiliates

AZ

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

Food Worker Relief Program – Assistance Listing No. 10.181 Recommendation: We recommend that the Organization strengthen its controls and processes to identify all procurement transactions, ensure the appropriate procurement policies and levels are followed and clearly documented, and to verify vend...

Food Worker Relief Program – Assistance Listing No. 10.181 Recommendation: We recommend that the Organization strengthen its controls and processes to identify all procurement transactions, ensure the appropriate procurement policies and levels are followed and clearly documented, and to verify vendors are not suspended or debarred. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has taken the follwing steps to ensure procurement policies are followed : 1) Management has begun the hiring process for additional staffing in the Procurement Department to help support all operations. 2) Management will review and update current policy to be in line with Federal Procurement policies. 3) Procurement department will provide training to all personnel authorized for purchases. Name(s) of the contact person(s) responsible for corrective action: Jesse Satterlee, Interim CFO, 778-730-1155 Nancy Lipman, SVP Compliance, 602-257-0700 Planned completion date for corrective action plan: 6/30/2024 – Ongoing action and Implementation

View Audit 298172

Finding 385067 (2023-002)

Material Weakness 2023

Mammoth Unified School District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

Reviewing all areas of this finding, the District will follow the procurement policy, in fact the District has reached out to PINCO and is now part of their Co-op.

View Audit 298160

Finding 385063 (2023-001)

Material Weakness 2023

Mammoth Unified School District

CA

Questioned Costs Eligibility Subrecipient Monitoring

Reviewing all areas of this finding, the District needs to assist with extra help from the district office and ensure that all student records are updated timely based on the review of income eligibility forms or direct certification information, plus additional training.

View Audit 298160 Questioned Costs: $1

Finding 385031 (2023-001)

Significant Deficiency 2023

Autonomous Municipality of Caguas

PR

HUD Housing Programs Subrecipient Monitoring Eligibility

The Municipality of Caguas PHA will implement internal controls which ensure that the families files conform to the program requirements for the annual recertifications. Each month the Program Manager or the persona assigned by the Director, will select a sample of files of each zone and verify the ...

The Municipality of Caguas PHA will implement internal controls which ensure that the families files conform to the program requirements for the annual recertifications. Each month the Program Manager or the persona assigned by the Director, will select a sample of files of each zone and verify the following: Voucher Size, Family Composition, income., Inspection Documents, Payment Standards, Utilities, and the rent calculation in the Form HUD-50058, Family Report and other required documents. Files without all the required documentation will be assigned to the respective Housing Office (HO). The HO must contact the family and request the necessary documentation in order to complete the tenant file. The HO will be required to complete all corrective actions within 15 days upon assignment. If additional time is needed, the Director or the person assigned will evaluate the case and may provide an additional 15 days for a maximum of 30 days.

View Audit 298127

Finding 385023 (2023-006)

Material Weakness 2023

Morris Brown College

GA

Subrecipient Monitoring Material Weakness

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The school’s IT firm has taken the following steps to address GLBA Compliance in the following manner. Element 1: ADB Network Consultants LLC and its Delegated Partners will serve as the Morris Brown College Managed Cybersecu...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The school’s IT firm has taken the following steps to address GLBA Compliance in the following manner. Element 1: ADB Network Consultants LLC and its Delegated Partners will serve as the Morris Brown College Managed Cybersecurity Service Provider. ADB is responsible for overseeing and implementing and enforcing the institution’s information security program. Element 2: The risk assessment for MBC’s Cyber Security program is covered within the MBC Cyber-Security -Incident-Response document on pages 8 through 12 which includes Appendix B (Incident Categorization), Appendix C (Incident Impact Definitions and IRT Incident Severity & Response Classification Matrix), and Appendix D (IRT Incident Record Form). The system is designed to provide ongoing and updated Reporting. Element 3: Access to MBC’s network, data, and email system is permitted only to authorized users. Access is granted by MBC Authorized Personnel and/or IT service providers through the administrative console of the respective environment (Active Directory Domain Controller for network and data access, Microsoft 365 Admin Center for Outlook email access, and MBC Authorized Personnel and/or Security Guards for physical facilities access). Element 4: MBC Authorized Personnel and IT service providers will test the Cyber Security Incident Response Plan periodically, but at least annually to monitor the effectiveness of the safeguards it has implemented. Element 5: MBC’s IT service provider created a Cyber Security Incident Response Plan, which documents who and how MBC Authorized Personnel and IT service providers will respond to Cyber Security incidents. Element 6: MBC has a 2-year contract with its IT service provider, ADB Network Consultants LLC. The service contract lists and governs the services that the IT service provider and its partners will perform monthly. Element 7: Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the information security program (16 C.F.R. 314.4(g)). ADB Network Consultants LLC implemented a system that will log the activity of authorized users and prevent unauthorized network access. Email Threat Protection has also been setup. Person Responsible for Corrective Action Plan: Shermanetta Carter, CFO Anticipated Date of Completion: June 30, 2024

View Audit 298113

Finding 385012 (2023-002)

None 2023

Universidad Central De Bayamon INC

PR

Student Financial Aid Special Tests & Provisions Eligibility

Finding No. 2023–002 – Enrollment Reporting Name of Contact Person: Dr. Kendra Ortiz, Registrar Corrective Action Plan UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NS...

Finding No. 2023–002 – Enrollment Reporting Name of Contact Person: Dr. Kendra Ortiz, Registrar Corrective Action Plan UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University comply with the 60-day requirement, we have established an additional notification procedure. The Financial Aid Office will forward report of all Title IV student recipients classified as withdrawn to the Registrar's Office, this process consists of a reconciliation of the data. The Registrar's office will report the enrollment change of this cases to NSLDS within 60 days required. Anticipated completion date: Immediately.

View Audit 298066

Finding 385003 (2023-001)

Significant Deficiency 2023

University of Nebraska

NE

Subrecipient Monitoring Reporting

UNMC Sponsored Programs Accounting will have at least two individuals with access to the FSRS system. A reviewer will sign off on all monthly FFATA reports. This corrective action plan has been implemented effective March 2024. Anticipated Completion Date: March 6, 2024. Contact Name and Telephone...

UNMC Sponsored Programs Accounting will have at least two individuals with access to the FSRS system. A reviewer will sign off on all monthly FFATA reports. This corrective action plan has been implemented effective March 2024. Anticipated Completion Date: March 6, 2024. Contact Name and Telephone Number: Linda Combs, Manager, UNMC Sponsored Programs Accounting, 402-559-5825

View Audit 298065

Finding 384995 (2023-002)

Material Weakness 2023

Lincoln Parish School Board

LA

School Nutrition Programs Subrecipient Monitoring Cash Management

Reference # and title: 2023-002 Internal Control and Compliance over Financial Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of ...

Reference # and title: 2023-002 Internal Control and Compliance over Financial Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program AL #10.553 2023 National School Lunch Program AL #10.555 2023 Condition: Louisiana Department of Education (LDOE) requires the School Board to complete monthly claims for reimbursement for meals and snacks served to eligible students within 60 days of the following the last day of the month covered by the claim. Required internal controls over these claims for reimbursement required that all data for the claim be maintained and complete and accurate. Additionally, internal controls require that reports be reviewed by someone other than the person completing the claim. In testing a sample of two months, it was noted that the School Board did not have a review process of the claim by a second person before the claim was submitted. It was also noted that the School Board did not include all students that received meals in requesting for reimbursement as well as the School Board used the wrong CEP percentage in the request for reimbursement. In reviewing the full year’s claims to determine the amount over/under requested, it was noted that these errors caused the School Board to under request for reimbursement in the amount of $20,044. Corrective action planned: The Lincoln Parish School Board hired a new CNP Supervisor in November, 2023 and a new CNP secretary/bookkeeper in December, 2023. CEP reimbursement claim training was conducted on-site with CNP department staff on December 13, 2023, by: - Stephanie Loup – Executive Director of Nutrition – Louisiana Department of Education - Misty Woods – Director of School Food Service– Louisiana Department of Education During this training, the CEP free claim percentage for 2023-2024 was validated as 83.78% and a mock claim worksheet was completed with new administrative staff. This percentage will be validated annually. Regarding the review process of the CEP claim, we have implemented a two-check verification method for this process. Step One is related to the bookkeeper’s responsibilities. The bookkeeper collects and fills out the CNP Reimbursement Claim form in the CNP Claim portal, prints the completed form, and then signs and dates the form before it is submitted to the CNP Supervisor. Step Two is related to the CNP Supervisor’s responsibility. The Supervisor will conduct final review of the report data. If the report is accurate, the Supervisor signs and dates the printed form and returns the form to the Bookkeeper for filing with claim records. Then, the official claim is submitted electronically by the Bookkeeper via the State CNP Claim portal. Person responsible for corrective action: Mr. Cody Carrico, Supervisor of Food Service Phone: (318) 255-1474 Lincoln Parish School Board Fax: (318) 254-1220 1428 Arlington Street Ruston, LA 71270 Anticipated completion date: December 31, 2023 – Actively in place

View Audit 298062

Finding 384991 (2023-004)

Significant Deficiency 2023

Emmaus Bible College

IA

Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The College concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The College has implemented annual cybersecurity training for employees. The College is in process on u...

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The College concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The College has implemented annual cybersecurity training for employees. The College is in process on updating its risk assessment, improving safeguards, updating and improving policies and procedures, improving continuous monitoring, and updating incident response plan. The Director of Technology Services will present written status report to the board at the next relevant meeting after March 2024 and this will be done on an annual basis going forward. Person Responsible for Corrective Action Plan: Steven Jabini, Director of Technology Services Anticipated Date of Completion: May 31, 2024

View Audit 298054

Finding 384974 (2023-001)

Significant Deficiency 2023

Community Service Society of New York

NY

Subrecipient Monitoring Reporting Significant Deficiency

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports five days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are made...

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports five days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are made to the subrecipients and, in turn, proper and timely reports are filed by the Society with the State of New York. There are instances when, because of delays in receipt of information from the subrecipients, or information from the subrecipients needs to be revised, reports are submitted late to the State of New York. The Society notifies the State of New York when reports will be submitted late. In addition, the Society is working with its subrecipients to improve their reporting procedures, as well as the timeliness and accuracy of their reports. This will result in the Society improving the timeliness of its reporting to the State of New York.

View Audit 298015

Finding 384970 (2023-005)

Significant Deficiency 2023

Grants-Cibola County Schools

NM

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

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

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

View Audit 298006

Finding 384924 (2023-034)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

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

View Audit 297960

Finding 384922 (2023-033)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements tha...

The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Please note that the scheduled completion date is 2/1/23 as the same FFATA reporting finding was identified for a different program during the SFY22 Single Audit, and the corrective action plan was applied across the Department as a whole. The FFATA issues identified in the SFY23 Single Audit pre-dated the implementation of our corrective action plan. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Lillian Smith, VDH Financial Administrator lillian.smith@vermont.gov Jessica Brown, VDH Financial Manager jessica.p.brown@vermont.gov Megan Hoke, VDH Financial Director megan.hoke@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384910 (2023-030)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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

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

View Audit 297960

Finding 384901 (2023-024)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements tha...

The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Please note that the scheduled completion date is 2/1/23 as the same FFATA reporting finding was identified for a different program during the SFY22 Single Audit, and the corrective action plan was applied across the Department as a whole. The FFATA issues identified in the SFY23 Single Audit pre-dated the implementation of our corrective action plan. Scheduled Completion Date of Corrective Action Plan: 2/1/2023 Contacts for Corrective Action Plan: Lillian Smith, VDH Financial Administrator lillian.smith@vermont.gov Jessica Brown, VDH Financial Manager jessica.p.brown@vermont.gov Megan Hoke, VDH Financial Director megan.hoke@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384895 (2023-021)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Due to staff vacancies and turnover that arose in the DCF Quality Assurance & Reporting (QA&R) team during the summer of 2022, there was insufficient intra-team communication and training regarding FFATA reporting requirements. As of January 1, 2024, then, formal procedures and training will be put...

Due to staff vacancies and turnover that arose in the DCF Quality Assurance & Reporting (QA&R) team during the summer of 2022, there was insufficient intra-team communication and training regarding FFATA reporting requirements. As of January 1, 2024, then, formal procedures and training will be put in place to ensure all QA&R staff are prepared to execute their responsibilities pertaining to FFATA reporting requirements. Further, in order to monitor FFATA reporting compliance going forward, AHS Internal Audit Group (IAG) will include LIHEAP subawards in its annual review. Scheduled Completion Date of the Corrective Action Plan: January 1, 2024: FFATA reporting procedures and training in place and operating. December 31, 2024: Annual review of FFATA rules and regulations including subawards review. Contacts for Corrective Action Plan: Melanie Rutledge, DCF Financial Director I melanie.rutledge@vermont.gov Megan Smeaton, DCF Financial Director IV megan.smeaton@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 297960

Finding 384889 (2023-020)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring § 200.303 § 200.332

UEI Missing - This issue was mainly caused by a mid-year change by our federal partners when they moved from the DUNS number to the UEI numbers. Our GMS system adjusted for the change but some of our grant awards did not include UEI numbers at that time. We will raise this issue with our Vendor to...

UEI Missing - This issue was mainly caused by a mid-year change by our federal partners when they moved from the DUNS number to the UEI numbers. Our GMS system adjusted for the change but some of our grant awards did not include UEI numbers at that time. We will raise this issue with our Vendor to ensure the UEI shows on all awards going forward. We will also make sure the UEI is reviewed during our grant review process. Obligation by this action- This is an issue with how our GMS processes grant amendments, on amendments beyond the first amendment the GMS shows the total change vs the change for this action. AOE will raise this issue with our vendor and will try to get it corrected prior to when FY25 grant amendments are processed. This will be a critical request to our Vendor. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 10/01/2024

View Audit 297960

Finding 384877 (2023-018)

Material Weakness 2023

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we s...

To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year. The work will be done by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024

View Audit 297960

Finding 384876 (2023-017)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring § 200.303 § 200.332

UEI Missing - This issue was mainly caused by a mid-year change by our federal partners when they moved from the DUNS number to the UEI numbers. Our GMS system adjusted for the change but some of our grant awards did not include UEI numbers at that time. We will raise this issue with our Vendor to...

UEI Missing - This issue was mainly caused by a mid-year change by our federal partners when they moved from the DUNS number to the UEI numbers. Our GMS system adjusted for the change but some of our grant awards did not include UEI numbers at that time. We will raise this issue with our Vendor to ensure the UEI shows on all awards going forward. We will also make sure the UEI is reviewed during our grant review process. Obligation by this action- This is an issue with how our GMS processes grant amendments, on amendments beyond the first amendment the GMS shows the total change vs the change for this action. AOE will raise this issue with our vendor and will try to get it corrected prior to when FY25 grant amendments are processed. This will be a critical request to our Vendor. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 10/01/2024

View Audit 297960

Finding 384875 (2023-016)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we s...

To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. In March 2023 we started reconciliations and plan to continue reconciling a couple times each year. The work will be done by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. We will look into the Batch upload process to allow for data to be entered into the system easier. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 5/01/2024

View Audit 297960

Finding 384870 (2023-014)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring § 200.303 § 200.332

This is an issue with how our GMS processes grant amendments. On amendments beyond the first amendment the GMS shows the total change vs the change for this action. AOE will raise this issue with our vendor and will try to get it corrected prior to when FY25 grant amendments are processed. This wil...

This is an issue with how our GMS processes grant amendments. On amendments beyond the first amendment the GMS shows the total change vs the change for this action. AOE will raise this issue with our vendor and will try to get it corrected prior to when FY25 grant amendments are processed. This will be a critical request to our Vendor. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 10/01/2024

View Audit 297960

Finding 384860 (2023-011)

Significant Deficiency 2023

State of Vermont

VT

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

FAIN (Federal Award Identification Number) and Federal Award Date: The following action has been implemented to include the FAIN & Award date on all awards for ALN 20.509: All awards executed for Public Transit will include a “Grant Insert Sheet”. The Grant Insert Sheet will be identified on the Par...

FAIN (Federal Award Identification Number) and Federal Award Date: The following action has been implemented to include the FAIN & Award date on all awards for ALN 20.509: All awards executed for Public Transit will include a “Grant Insert Sheet”. The Grant Insert Sheet will be identified on the Part 1 Grant award detail document. Box “36” titled FAIN, will include text that reads “See attachment B”. The Grant Insert Sheet is a document that is completed by the Public Transit Unit and is provided to the Grants Unit for award execution. This sheet includes detailed information related to the award. To address the deficiency, The Grant Insert sheet has been updated to include FAIN Numbers and the Federal Award Date. To ensure the Agency of Transportation meets this compliance requirement, the Grants Unit will verify this information is included prior to award execution. Anticipated completion date: This action went into effect as of January 12, 2024. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov Tricia Scribner, Grants Unit Manager tricia.scribner@vermont.gov Management Review Schedules In the past, The Public Transit Program has used the State Fiscal year for the timing/scheduling of the 3-year Management Reviews. For example, if the completion of the last Management Review occurred in FY 2020, then we would ensure a new Management Review began at any time during FY2023. We understand this could lead to more than exactly 3 years between these reviews. Due to this finding, we will now establish a starting month/date for each provider, with 3-year intervals between the start of each Management Review. We have attached the updated schedule and will adhere to this from this day forward. Anticipated completion date: As of December 27, 2023, the updated Management Review Schedule is in effect. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov

View Audit 297960

Finding 384859 (2023-010)

Significant Deficiency 2023

State of Vermont

VT

Subrecipient Monitoring Reporting § 200.303 § 200.332

The Agency had last year recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency provided Uniform Guidance training in February and March of 2023. The Agency developed and delivered a subrecipient monitoring framework which included tools to fac...

The Agency had last year recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency provided Uniform Guidance training in February and March of 2023. The Agency developed and delivered a subrecipient monitoring framework which included tools to facilitate subrecipient risk assessments, subrecipient monitoring plans based on the initial risk assessments, testing of transaction records, desk reviews of subrecipients, and corrective action plans. The Agency performed desk reviews for agencies and departments in the first six months of Fiscal Year 2024. As part of the desk review process, preliminary reports are issued, mitigation opportunities are presented, mitigation opportunities are implemented as appropriate, and final reports are shared across staff and management. The Agency will continue to provide oversight and monitoring for agency adherence to subrecipient monitoring procedures, informed by our ongoing agency and program-level compliance risk assessments, which include factors such as program complexity and history of audit findings. Scheduled Completion Date of Corrective Action Plan: Completed: July, 2023: Subrecipient Monitoring Framework Provided to Agencies & Departments Completed: December, 2023: Sampling completed by Agency Expected: April, 2024: Post-Sampling Follow-up with Agencies and Departments Expected: June, 2024: Continuing Monitoring and Technical Assistance Processes Expected: June, 2024: Additional Training for Agencies and Departments Contacts for Corrective Action Plan: Douglas Farnham Chief Recovery Officer, Vermont State Recovery Office Douglas.Farnham@vermont.gov (802) 585-8119 Ethan Hurley Director of Finance & Operations, Vermont State Recovery Office Ethan.Hurley@vermont.gov (802) 461-5317

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