Corrective Action Plans

Finding Reference 2025-003 Personnel Responsible for Corrective Action: Policies and procedures will be supervised by Tracie Thomas (Chief Operating Officer). Policies and procedures will be implemented and maintained by Laura Froese (Accounting Manager), Westen Gehring (Grants Specialist), and Brenna Wilcox (Accounting Specialist). Anticipated Completion Date: Immediately. Views of Responsible Officials and Planned Corrective Action: Concur. Corrective Actions Planned: The Land Institute identified that the exception noted occurred during the initial implementation phase of updated procurement policies developed in response to the FY23 Single Audit finding. The instance was due to a breakdown in timing and communication rather than a deficiency in the policies themselves. To prevent recurrence, The Land Institute has implemented a pre-award procurement control requiring that all sole source justifications and suspension and debarment verifications be completed, reviewed, and approved prior to contract execution and prior to any costs being charged to a federal award. Finance and Grants personnel will verify completion of required documentation before processing payments or coding expenses to federal awards. Training has been provided to relevant staff to reinforce procurement requirements, including timing and documentation expectations. Ongoing monitoring procedures have been implemented to ensure continued compliance.

Reference Number: 2025-017 Prior Year Finding: No 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: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The VDH Director of Communications will ensure that copies of any cost analysis performed as part of the RFP review process are collected from department staff and saved in the procurement files for the associated contract. Documentation will be maintained according to Administrative Bulletin 3.5 and federal records retention requirements. Scheduled Completion Date of Corrective Action Plan: March 1, 2026 Contacts for Corrective Action Plan: Katie Warchut, Director of Communications, Vermont Department of Health, katie.warchut@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

Reference Number: 2024-014 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/3/2021 – 12/31/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan The Agency of Administration has written and published Procurement and Contracting Procedures known as Bulletin 3.5. Section 9.3.14 (Documentation) details the required documentation that should be placed in the contract file. The Department of Buildings and General Services (a department of the Agency of Administration), Office of Purchasing and Contracting, is charged with maintaining procurement documentation on behalf of the Office of the Secretary of Administration. Department of Buildings and General Services, Office of Purchasing and Contracting, will conduct an internal staff re-training on Bulletin 3.5, Section 9.3.14. In addition, the Office of Purchasing and Contracting will perform an internal review for procurements completed by the Secretary’s office to ensure they are in compliance. Scheduled Completion Date of Corrective Action Plan: BGS OPC Staff Training – June 30, 2025 BGS OPC Internal Review – December 31, 2025 Contacts for Corrective Action Plan: Doug Farnham, Chief Recovery Officer douglas.farnham@vermont.gov Deb Damore, Director, Office of Purchasing and Contracting deborah.damore@vermont.gov

Reference Number: 2024-006 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: Due to the unique nature of a tropical storm hitting Vermont in 2011, which flooded the Waterbury State Office Complex (the Complex), all state operations were forced to temporarily move from the Complex to another facility while damages to the structure were remedied. Due to the significant number of records needing to be moved, the records in question may have been lost in this transition. Since then, we have instituted a new process that requires all bid submissions to be received and stored electronically. All bid submissions, cost analysis, and scoring of the bids are now kept in our electronic files instead of hard copy preventing physical damage or loss of records. Scheduled Completion Date of Corrective Action Plan: Completed and in full effect since December 31, 2020. Contacts for Corrective Action Plan: Melanie Rutledge, Financial Director I melanie.rutledge@vermont.gov Melanie Smit, Administrative Services Director I melanie.smit@vermont.gov Megan Smeaton, Financial Director IV megan.smeaton@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Finding Number: 2022-001 Type: Significant deficiency in internal control Condition per Auditor: The District ended the fiscal year with fund equity in excess of 3 months' average expenditure in the Food Service Fund Planned Corrective Action: The District will review its policies and procedures and implement a process to periodically review the fund equity of the food service program and make spending adjustments as needed. Anticipated Completion Date: Immediate Responsible Contact Person: Superintendent and LEA Business Manager