Corrective Action Plans

Finding 37931 (2022-002)

Material Weakness 2022

WA

Subrecipient Monitoring Allowable Costs / Cost Principles School Nutrition Programs

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls to ensure compliance with federal Title I requirements for allocating funds to school buildings. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Ma...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls to ensure compliance with federal Title I requirements for allocating funds to school buildings. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 Tel: (509) 932-4565 Ext: 3031 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Anticipated date to complete the corrective action: 08/31/2023

View Audit 29466

Finding 37930 (2022-001)

Material Weakness 2022

Wahluke School District No.73

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal requirements for time-and-effort documentation. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 ...

Finding ref number: 2022-001 Finding caption: The District?s internal controls were inadequate for ensuring compliance with federal requirements for time-and-effort documentation. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 Tel: (509) 932-4565 Ext: 3031 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. ? The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. Anticipated date to complete the corrective action: 08/31/2023

View Audit 29466

Finding 37924 (2022-003)

Significant Deficiency 2022

Help-New Mexico, Inc.

NM

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management § 200.514

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Agriculture 2022-003 SNAP Employment and Training Program ? Assistance Listing No. 10.537 Recommendation: We recommend that management improve internal control monitoring activities and provide training to staff regarding timely reimbursemen...

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Agriculture 2022-003 SNAP Employment and Training Program ? Assistance Listing No. 10.537 Recommendation: We recommend that management improve internal control monitoring activities and provide training to staff regarding timely reimbursement requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This deficiency was caused as a result of the change in personnel. In late 2021, all of the accounting personnel for Help left the company and were replaced. Unfortunately, due to this untimely and unexpected departure of key personnel, Help management was unaware of some necessary processes and was not able to properly train the new staff in all matters. Help management will provide additional training to those responsible for preparation and review of the reimbursement requests. In addition, processes will be implemented to ensure that all reimbursement requests are completed on a timely basis in accordance with funding requirements. Names of the contact persons responsible for corrective action: Alicia Nunez, CFO, 602-257-0700 Maria Spelleri, General Counsel, 602-257-6719 Planned completion date for corrective action plan: June 2023

View Audit 38099

Finding 37915 (2022-002)

Significant Deficiency 2022

Family Services of Westchester, Inc.

NY

Reporting Subrecipient Monitoring

Family Services of Westchester, Inc. Corrective Action Plan February 27, 2023 U.S. Department of Health and Human Services Family Services of Westchester, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 1301 Avenue ...

Family Services of Westchester, Inc. Corrective Action Plan February 27, 2023 U.S. Department of Health and Human Services Family Services of Westchester, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number in the schedule. FINDINGS ? FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Head Start Cluster: Assistance Listing Number 93.600 SIGNIFICANT DEFICIENCIES Finding 2022-002 ? Reporting Recommendation: We recommend that the Organization register in the Federal Funding and Accountability and Transparency Act Subaward Reporting System (FSRS) and timely report the required subaward information as required by the Transparency Act. Action Taken There is a specific Head Start requirement that all direct subawards with an obligated amount over a $30,000 threshold must be reported as such by no later than the end of the following month of the agreement to FSRS. There was an oversight on the specifics of this requirement resulting in a late report. Going forward, workflow has been amended to take this requirement into account and to submit the report on a timely basis, no later than the end of the following month of the agreement. Completion Date: February 27, 2023 If the U.S Department of Health and Human Services has questions regarding this plan, please call Maria Mazzotta at (914)502-1470. Sincerely yours, Maria Mazzotta Chief Finance Officer

View Audit 34307

Finding 37914 (2022-001)

Significant Deficiency 2022

Family Services of Westchester, Inc.

NY

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Family Services of Westchester, Inc. Corrective Action Plan February 27, 2023 U.S. Department of Health and Human Services Family Services of Westchester, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 1301 Avenue ...

Family Services of Westchester, Inc. Corrective Action Plan February 27, 2023 U.S. Department of Health and Human Services Family Services of Westchester, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number in the schedule. FINDINGS ? FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Head Start Cluster: Assistance Listing Number 93.600 SIGNIFICANT DEFICIENCIES Finding 2022-001 ? Inaccurate SEFA, Reporting Recommendation: We recommend that the Organization strengthen its policies and procedures for the identification of Federal awards, including pass-through federal funds to subrecipients, to ensure a complete and accurate SEFA is prepared in a timely manner and in accordance with the requirements of the Uniform Guidance. Action Taken There was an oversight in the completion of the SEFA resulting in not including passthrough federal funds given to subrecipients. Going forward, workflow has been amended to take into account any subawards given to subrecipients of federal funds, to ensure inclusion of the information in the SEFA. Completion Date: February 27, 2023 If the U.S Department of Health and Human Services has questions regarding this plan, please call Maria Mazzotta at (914)502-1470. Sincerely yours, Maria Mazzotta Chief Finance Officer

View Audit 34307

Finding 37913 (2022-002)

Significant Deficiency 2022

Butler County Health Center

MO

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency

FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF AGRICULTURE (USDA) 2022-002 Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) ? Assistance Listing No. 10.557; Contract No. ERS04521039; Grant period ? Year Ended December 31, 2021. Signif...

FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF AGRICULTURE (USDA) 2022-002 Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) ? Assistance Listing No. 10.557; Contract No. ERS04521039; Grant period ? Year Ended December 31, 2021. Significant Deficiency: As discussed at Finding 2021-001, adequate segregation of duties is not present with Butler County Health Center, including duties within the WIC federal program. Employee turnover of key positions recently impacts the application of adequate segregation of duties. These areas should be reviewed periodically, and consideration given to improving the segregation of duties within the Center. CORRECTIVE ACTION PLAN The Operations Director is the lead staff on Financial Statements. Financial Statements will be filed on a shared "G" drive with access allowed to the Operations Director, Administrator and Office Manager. Al l employee passwords will be submitted to the Operations Director and placed on a shared G" drive with access allowed to the Administrator. This action will be done annually. The Administrator and Operations Director receives a hard copy of the monthly Financial Statements from KMT. This Financial Statement is kept in a binder in the Operations Director's Office where the Administrator and Office Manager have access. The Butler County Health Department will obtain in writing the objectives of the services that KMT will provide and what they are responsible for, as well as what the Health Department is responsible for in regard to making sure the books are complete and accurate. Contact Person: Emily Goodin, Administrator

View Audit 31352

Finding 37912 (2022-003)

Significant Deficiency 2022

Butler County Health Center

MO

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency

DEPARTMENT OF HEALTH AND SENIOR SERVICES 2022-003 Immunization Cooperative Agreements - Assistance Listing No. 93.268; Grant period ? Year Ended December 31, 2022. Significant Deficiency: As discussed at Finding 2022-001, adequate segregation of duties is not present with Butler County Health C...

DEPARTMENT OF HEALTH AND SENIOR SERVICES 2022-003 Immunization Cooperative Agreements - Assistance Listing No. 93.268; Grant period ? Year Ended December 31, 2022. Significant Deficiency: As discussed at Finding 2022-001, adequate segregation of duties is not present with Butler County Health Center, including duties within the Immunization Cooperative Agreements federal program. These areas should be reviewed periodically, and consideration given to improving the segregation of duties within the Center. CORRECTIVE ACTION PLAN The Operations Director is the lead staff on Financial Statements. Financial Statements will be filed on a shared "G" drive with access allowed to the Operations Director, Administrator and Office Manager. All employee passwords will be submitted to the Operations Director and placed on a shared G" drive with access allowed to the Administrator. This action will be done annually. The Administrator and Operations Director receives a hard copy of the monthly Financial Statements from KMT. This Financial Statement is kept in a binder in the Operations Director's Office where the Administrator and Office Manager have access. The Butler County Health Department will obtain in writing the objectives of the services that KMT will provide and what they are responsible for, as well as what the Health Department is responsible for in regard to making sure the books are complete and accurate. Contact Person: Emily Goodin, Administrator

View Audit 31352

Finding 37900 (2022-001)

Material Weakness 2022

Foxfire High School

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions

Finding Number: 2022-001 Planned Corrective Action: Improve internal controls to make sure the clauses concerning prevailing wage rate are stated in contract if needed and contractor submit copies of payroll records to confirm that prevailing wages were paid. Anticipated Completion Date: 01/09/2023 ...

Finding Number: 2022-001 Planned Corrective Action: Improve internal controls to make sure the clauses concerning prevailing wage rate are stated in contract if needed and contractor submit copies of payroll records to confirm that prevailing wages were paid. Anticipated Completion Date: 01/09/2023 Responsible Contact Person: Lewis Sidwell, Treasurer

View Audit 36938

Finding 37887 (2022-001)

Significant Deficiency 2022

Omak School District No. 19

WA

Subrecipient Monitoring Equipment & Real Property Management Procurement, Suspension & Debarment

Finding ref number:2022-001 Finding caption:The District did not have adequate internal controls over allowable activities and costs, and restricted purpose requirements. Name, address, and telephone of District contact person: Scott Haeberle 619 W. Bartlett Avenue Omak, WA 98841 (509) 826-0320 C...

Finding ref number:2022-001 Finding caption:The District did not have adequate internal controls over allowable activities and costs, and restricted purpose requirements. Name, address, and telephone of District contact person: Scott Haeberle 619 W. Bartlett Avenue Omak, WA 98841 (509) 826-0320 Corrective action the auditee plans to take in response to the finding: To ensure future compliance with Federal requirements related to the Emergency Connectivity Fund grant, the District will confirm and document the unmet needs for all students or staff that receive use of equipment or services funded by the program. All staff associated with the grant will be provided with the requirements for determining unmet needs and eligibility for claim. Anticipated date to complete the corrective action: September 1, 2023

View Audit 35202

Finding 37885 (2022-001)

None 2022

Ryder Assisted Care Ii, Inc.

PR

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 day...

Finding Number: 2022-1 Payment of invoices before 30 days of received. The project staff was oriented about the importance of make a payment 30 days after receive the invoice. The plan of correction empathizes in verify weekly the supplier?s invoices and establish a payment date not more than 30 days of the invoice was received.

View Audit 32670

Finding 37881 (2022-001)

Significant Deficiency 2022

Norma Locklear Pitts Senior Community, Inc.

SC

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Comments on the Finding (#2022-001) and Each Recommendation: The Corporation is not in compliance with the terms of the Section 202 Regulatory Agreement. As of September 30, 2022, the residual receipts fund is underfunded by $9,900. Management should obtain HUD approval before making withdrawals fro...

Comments on the Finding (#2022-001) and Each Recommendation: The Corporation is not in compliance with the terms of the Section 202 Regulatory Agreement. As of September 30, 2022, the residual receipts fund is underfunded by $9,900. Management should obtain HUD approval before making withdrawals from the residual receipts fund. Management should transfer $9,900 to the residual receipts fund. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation.

View Audit 32084 Questioned Costs: $1

Finding 37871 (2022-001)

Significant Deficiency 2022

International Institute of Metropolitan St. Louis and Subsidiary

MO

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2022-001 Personnel Responsible For Corrective Action: Paul Costigan, State Refugee Coordinator Anticipated Completion Date: June 2023 Correction Action Plan: Paul Costigan, State Refugee Coordinator, failed to submit one of two required federal reports on awards to subcontractors for FY2...

Finding 2022-001 Personnel Responsible For Corrective Action: Paul Costigan, State Refugee Coordinator Anticipated Completion Date: June 2023 Correction Action Plan: Paul Costigan, State Refugee Coordinator, failed to submit one of two required federal reports on awards to subcontractors for FY22. Paul has since completed the FFATA for FY22 and FY23 and the completion of this report is now a recurring calendar item.

View Audit 35654

Finding 37859 (2022-004)

Significant Deficiency 2022

Door County Economic Development Corporation

WI

Subrecipient Monitoring Reporting Significant Deficiency

2022-004 Special Reporting Supporting Documentation Reporting ? Economic Development Assistance?Revolving Loan Fund ? CFDA No. 11.307 Recommendation: Door County Economic Development Corporation should create an internal monitoring system to document future review of the ED-209 reports and verify t...

2022-004 Special Reporting Supporting Documentation Reporting ? Economic Development Assistance?Revolving Loan Fund ? CFDA No. 11.307 Recommendation: Door County Economic Development Corporation should create an internal monitoring system to document future review of the ED-209 reports and verify that supporting documentation is attached and retained for review during future audits and to also ensure future reports are filed prior to their due date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will continue working to ensure that all activities related to federal award programs are filed in a timely manner and retained for review. Name(s) of the contact person(s) responsible for corrective action: Michelle Lawrie Planned completion date for corrective action plan: Ongoing

View Audit 28721

Finding 37857 (2022-004)

Significant Deficiency 2022

Ainsworth Airport Authority

NE

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

The Authority relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The Authority reviews schedule of expenditures of federal awards and approves all adjustments.

View Audit 25541

Finding 37847 (2022-001)

Material Weakness 2022

Attalla City Board of Education

AL

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Reference Number: 2022-001 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control and Compliance Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance CFDA Number and Title: 84.425 ? COVID-19 Education Stabilization Fund Fede...

Reference Number: 2022-001 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control and Compliance Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance CFDA Number and Title: 84.425 ? COVID-19 Education Stabilization Fund Federal Award Agency: U.S. Department of Education Pass-through Entity: Alabama Department of Education Funds from COVID-19 Education Stabilization Fund (ESF) were used to fund construction contracts in excess of $2,000 without the inclusion of prevailing wage rate clauses as required by Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the ?Davis-Bacon Act?). The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in construction contracts. Therefore, the construction project contract awarded during the fiscal year did not include prevailing wage rate clauses nor did the contractors submit weekly certified payrolls to the Board. Response: Management will implement controls to ensure future contracts funded with COVID-19 Education Stabilization Funds (ESSER) in excess of $2,000 specify applicability of wage rate requirements. Anticipated Completion Date: Contact Person(s): Laura Leak, Chief School Financial Officer

View Audit 31996 Questioned Costs: $1

Finding 37796 (2022-104)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Reporting Special Tests & Provisions § 200.303

Assistance Listing number and name: 84.031 Higher Education ? Institutional Aid Award numbers and years: P031S150032, October 1, 2015 through September 30, 2021 P031S150098, October 1, 2015 through September 30, 2021 P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1...

Assistance Listing number and name: 84.031 Higher Education ? Institutional Aid Award numbers and years: P031S150032, October 1, 2015 through September 30, 2021 P031S150098, October 1, 2015 through September 30, 2021 P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096, October 1, 2020 through September 30, 2025 P031S200081, October 1, 2020 through September 30, 2025 P031C210057, October 1, 2021 through September 30, 2026 P031C210077, October 1, 2021 through September 30, 2026 Federal Agency: U.S. Department of Education Compliance Requirements: Reporting and special tests and provisions Questioned costs: Unknown Name of contact persons: Kristina Winterstein, Associate Controller Anticipated completion date: December 31, 2023 The District is aware of the importance of ensuring that all reporting related to federal monies is presented accurately and in accordance with federal regulations. The District will work with the MCCCD Foundation to review its current endowment agreements as well as the Foundation?s policies and procedures with regard to the investment of its U.S. Department of Education (ED) federal endowment funds to ensure compliance with current federal endowment regulations. Effective December 1, 2022, the District developed procedures to ensure that endowment reports are reviewed and submitted to ED on an annual basis and has designated the District?s Grants Accounting Manager as the central District employee who will monitor report submission and compliance with all applicable regulations. The District will continue to work with ED to gain access to online reporting and submission tools to ensure timely submission of required reports.

View Audit 29977 Questioned Costs: $1

Finding 37774 (2022-025)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Corrective Action Plan: 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 F...

Corrective Action Plan: 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. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed 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. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. 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: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446

Finding 37772 (2022-023)

Significant Deficiency 2022

State of Vermont

VT

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Corrective Action Plan: 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 ...

Corrective Action Plan: 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. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed 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. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446 Questioned Costs: $1

Finding 37769 (2022-021)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring Reporting § 200.303 § 200.332

Corrective Action Plan: The Agency has recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency has created Uniform Guidance trainings that began in February 2023 and continue in March. These trainings include reference materials such as desk re...

Corrective Action Plan: The Agency has recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency has created Uniform Guidance trainings that began in February 2023 and continue in March. These trainings include reference materials such as desk references, job aids, etc. As a follow-up to the training, we will be developing and delivering a subrecipient monitoring framework which includes tools to facilitate subrecipient risk assessments, subrecipient monitoring plans based on the initial risk assessment, testing of transaction records, desk reviews of low-risk subrecipients, and corrective action plans. Finally, we will be working to provide oversight and monitoring for agency adherence to subrecipient monitoring procedures, informed by program-level compliance risk assessment. Scheduled Completion Date of Corrective Action Plan: Completed: February 16, 2023: Uniform Guidance Training (Part 1) Expected: March, 2023: Uniform Guidance Training (Part 2) Expected: July, 2023: Subrecipient Monitoring Framework Provided to Agencies & Departments Expected: December, 2023: Sampling completed by Agency Expected: February, 2024: Post-Sampling Follow-up with Agencies and Departments Contacts for Corrective Action Plan: Doug Farnham Deputy Secretary, Agency of Administration Douglas.Farnham@vermont.gov (802) 585-8119 Holly S. Anderson Chief Financial Officer, Agency of Administration ? Financial Services Division Holly.S.Anderson@vermont.gov (802) 505-1177

View Audit 30446

Finding 37765 (2022-018)

Significant Deficiency 2022

State of Vermont

VT

Reporting Subrecipient Monitoring § 200.303 § 200.502

Corrective Action Plan: The Agency has recognized the need to improve our SEFA compilation process and has begun using a quarterly reconciliation process with all agencies and departments. We are currently reconciling data from VISION to the data submitted to the U.S. Treasury for ARPA-SLFRF Quart...

Corrective Action Plan: The Agency has recognized the need to improve our SEFA compilation process and has begun using a quarterly reconciliation process with all agencies and departments. We are currently reconciling data from VISION to the data submitted to the U.S. Treasury for ARPA-SLFRF Quarterly Reporting. We are using this new quarterly reconciliation process as a starting point to check Subrecipient expenditures against total expenditures, as well as reviewing Grant Accounts and reviewing Class Codes. We are checking all of our programs and looking at Beneficiaries vs. Subrecipients to ensure we are categorizing correctly at the macro level. There will be an enhanced collaboration internal to the Agency between the Department of Finance & Management and the Financial Services Division that will occur after agencies and departments submit their ACFR-9s used in the SEFA consolidation process to provide greater review and oversight. Scheduled Completion Date of Corrective Action Plan: Completed: February, 2023: Quarterly Reconciliation Process (VISION to Treasury) Expected: June, 2023: Subrecipient vs. Beneficiary classification review Expected: September, 2023: Collaboration between DFM and FSD for SEFA preparation

View Audit 30446

Finding 37757 (2022-017)

Significant Deficiency 2022

State of Vermont

VT

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

Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for...

Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37753 (2022-013)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Eligibility Material Weakness § 200.303

The Department acknowledges and accepts this finding, and as this is a repeat finding from last year?s ACFR audit, the Department maintains the same response and corrective action plan. The Pandemic Unemployment Assistance (PUA) program did not exist prior to the COVID-19 global health pandemic. Un...

The Department acknowledges and accepts this finding, and as this is a repeat finding from last year?s ACFR audit, the Department maintains the same response and corrective action plan. The Pandemic Unemployment Assistance (PUA) program did not exist prior to the COVID-19 global health pandemic. Unlike the unemployment insurance program, which has been in existence since 1935, the PUA program did not have the inherent checks and balances built into the system to ensure proper program administration. Instead, state workforce agencies were expected to build the PUA program from the ground up with little guidance from the USDOL all the while managing through a pandemic that caused unprecedented upheaval in the employment status of millions of citizens. It is accurate that the Vermont Department of Labor was not able to implement the necessary checks and balances into the PUA program to ensure proper program eligibility. As has been pointed out in the audit finding, it was not until nine months after the start of the PUA program that Congress passed legislation that required documentation to be provided to substantiate program eligibility. At that time, due to the significant and unprecedented strains on the Department of Labor?s resources, the newly established documentation requirements were not able to be implemented prior to the end of the PUA program. The Department acknowledges that the lack of the ability to review claimant financial eligibility may have resulted in improper payments. It is important to point out that UIPL 16-20, Change 4 was issued on January 8, 2021, providing no time for UI programs to implement the required changes while still continuing to provide vital economic assistance to tens of thousands of individuals. The only other recourse available to the Department at that time would have been to stop program payments from issuing until the new eligibility requirements were reviewed. This would have left claimants without benefits for months while the Department used our limited financial and staff resources to implement the necessary changes. This is the result of the continuously changing eligibility requirements built from hastily implemented legislation and program design. In calendar year 2022, the Department began the process of retroactively reviewing all PUA claims that were filed and paid after the date of UIPL 16-20, Change 4 to ensure that proper documentation was provided to ensure program eligibility. Where appropriate, claims are being placed into an overpayment status and collection efforts will ensue. Corrective Action Plan: As mentioned above, the Department was aware that it was unable to implement the documentation requirement for the PUA program as required by the amendments to the CARES Act. The Department had every intention of going back and retroactively reviewing PUA claims for documentation and requiring submission for those claims that lacked adequate documentation retroactively. The USDOL Regional Office is aware of the process identified by the Department to resolve this issue retroactively. The Department has begun this work in early 2022 and will continue this review for PUA program eligibility for as long as USDOL provides the funding to do so until the Department has reviewed all PUA claims filed in calendar year 2021. Scheduled Completion Date of Corrective Action Plan: June 30, 2024 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37751 (2022-011)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

To ensure complete accurate reporting into the FSRS, the Agency shall implement the following steps: 1. Responsible staff will review Training Resources on the FFATA Home Page on an ongoing basis. 2. When Grant Agreements and Amendments are executed, email notifications to staff will be saved fro...

To ensure complete accurate reporting into the FSRS, the Agency shall implement the following steps: 1. Responsible staff will review Training Resources on the FFATA Home Page on an ongoing basis. 2. When Grant Agreements and Amendments are executed, email notifications to staff will be saved from the Grants Management Analyst and reviewed the 3rd Monday of each month they are received by both the Grants Management Specialist and Supervisor. 3. Once review is completed and details confirmed, Grant Agreement & Amendment Data will be reported into FFATA, by the Grants Management Specialist. 4. After Reports are completed in FFATA for the Executed Grant Agreements and Amendments, Grants Management Specialist will send an email to both the Grants Management Analyst notifying completion of the Reports and also to Supervisor, to review reports that the grant, fund amounts, and obligation dates are correct. 5. If any errors, the Supervisor, will notify the Grants Management Specialist that changes are required ? repeat (4.) notification to Supervisor when corrections in FFATA are complete to review and verify. Scheduled Completion Date for Corrective Action Plan: Completed: February 1, 2023 Point of contact: Ann Karlene Kroll, Federal Programs Director, annkarlene.kroll@vermont.gov, 802-828-5225.

View Audit 30446

Finding 37750 (2022-010)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring § 200.303 § 200.332 § 200.501

The Supervisor and Director of the CDBG program are now meeting weekly with the staff person assigned for review the Single Audits to understand the workload and assist in ensuring the backlog and the current audits are all reviewed in a timely manner. Additionally, going forward, the Agency is wo...

The Supervisor and Director of the CDBG program are now meeting weekly with the staff person assigned for review the Single Audits to understand the workload and assist in ensuring the backlog and the current audits are all reviewed in a timely manner. Additionally, going forward, the Agency is working to fund an agency-wide compliance officer to ensure impartial oversight of the agencies programs with regard to federal requirements (including single audit review), as well as avoiding taking the time of the CDBG program staff away from their duties. Scheduled Completion Date for Corrective Action Plan: Completed: Reviewed audits selected for testing September 30, 2023: Supervisor and Director have assisted in reviewing to ensure backlog brought current August 30, 2023: new position for Agency-wide compliance officer funded and position-filled Point of Contact: Ann Karlene Kroll, Federal Programs Director annkarlene.kroll@vermont.gov; (802) 828-5225.

View Audit 30446

Finding 37734 (2022-006)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Corrective Action Plan: 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 ...

Corrective Action Plan: 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. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed 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. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446

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