Corrective Action Plans

Finding 540685 (2024-032)

Material Weakness 2024

NH

Special Tests & Provisions Subrecipient Monitoring Cash Management § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) State Agency: NH Department of Safety, Division of Homeland Security and Emergency Management Audit Contact: Matthew Hotchkiss and Austin Brown Telephone: 602...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) State Agency: NH Department of Safety, Division of Homeland Security and Emergency Management Audit Contact: Matthew Hotchkiss and Austin Brown Telephone: 602-271-2231 E-mail address: Matthew.A.Hotchkiss@dos.nh.gov and NHPA@dos.nh.gov Audit Report Reference: 2024-032, 2023-021 Special Tests and Provisions - Project Accounting Anticipated Completion Date: April 30, 2025 Corrective Action Planned: HSEM concurs with finding 001-A. This issue was discovered during FEMA’s financial monitoring site visit in March 2024. To resolve this issue, HSEM drafted a Delegation of Authority letter which was filed with FEMA in November 2024. A copy of the DOA is attached to this response and was supplied to KPMG during the audit. The control and review concern of this issue was previously addressed by establishing a review process between the Accountant IV, Administrator II, and the Deputy Director prior to the submittal of all 425s. These controls were in place during the audit period but were not documented. Please note that inaccuracies were not found during the audit on the filed 425 reports. In the future, HSEM will ensure that the review process is documented. HSEM concurs with Finding 001-B and is taking immediate action to review and strengthen its procedures regarding FFATA filing. As of March 8, the Federal FFATA filing process has shifted to SAM.gov for report submissions. In response, HSEM is swiftly updating its internal procedures to guarantee the timely and accurate filing of FFATA reports. These updates will be incorporated into a comprehensive Quick Reference Guide, designed to provide programmatic staff with clear, efficient instructions for completing reports. Additionally, a robust review process will be instituted for programmatic supervisors to ensure strict adherence to the updated procedures. Programmatic supervisors, who will be responsible for conducting these reviews, were informed of the required process change on March 11, 2025. To ensure a smooth transition and full compliance, remedial training will be provided to all programmatic staff upon completion of the Quick Reference Guide review and update, no later than April 15, 2025.

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Finding 540684 (2024-031)

Material Weakness 2024

State of New Hampshire

NH

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 96.001 Social Security, Disability Insurance State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 20...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 96.001 Social Security, Disability Insurance State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-031, 2023-020 - Special Tests and Provisions – Qualified Providers Anticipated Completion Date: June 30, 2025 Corrective Action Planned: Management concurs with the finding above. The NH DDS will have updated the written policies and procedures in place that ensure the validly (non-expired) of medical licenses for providers, as well as suspension and debarment status of providers. Policies will be in place for pre-hire interested parties, as well as more than annual re-reviews. Aside from written policies and procedures, we will continue to update a spreadsheet to be completed for each individual review done and we will maintain a documents folder for each individual to retain electronic proofs in. Proof will be retained for 6 years. The Administrator continues to meet with the Professional Relations Officer every two weeks. These will be status calls of ensuring that each and every provider that we use is licensed, is not suspended or debarred from practicing, that they all each have rows on the spreadsheet, have folders, and these folders contain the individuals proof that the reviews have and are being done on, before and after a provider begins with the DDS and there is an electronic date stamp. The Administrator meets with the CE Scheduler’s Supervisor every two weeks. Time during these calls will be spent ensuring that the schedulers are only scheduling with licensed medical providers who have had their licenses checked by the Professional Relations Officer. The Disability Case Processing System (DCPS) is in the process of implementing consultative evaluation providers licensing features that include a CE Scheduler will not be able to schedule an evaluation with a provider who is not license verified or who has an expired license. The anticipated roll out for this feature will be in FFY25 (October 2024-September 2025). This will ensure that zero CE appointment will be scheduled with an unlicensed/expired provider. This will not eliminate the need for license and sanction checks and will not eliminate the need for documentation and proofs retention. In the event licensing and sanction checks are not completed and appropriately documented, date stamped, and proofs stored, this responsibility will shift to other DDS staff.

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Finding 540683 (2024-030)

Material Weakness 2024

State of New Hampshire

NH

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 96.001 Social Security, Disability Insurance State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 20...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 96.001 Social Security, Disability Insurance State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-030, 2023-019 - Reporting Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We have updated our processes as demonstrated with the boxes on line 7 being checked on the newer reports and will continue to follow this action on all future reports. NH SSDI will update/develop procedures for fiscal reporting. Spreadsheets used to create federal reports will be updated to clearly link information used and will be locked and saved as supporting documentation. Additionally, the NH SSDI will update its internal controls to include a second review and approval of all federal reports.

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Finding 540642 (2024-014)

Material Weakness 2024

State of New Hampshire

NH

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Referenc...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-014, 2023-008; 2022-013, 2022-016; 2021-013, 2021-015 - Reporting Anticipated Completion Date: 06/30/2025 Corrective Action Planned: The NHED concurs with this finding. We acknowledge these discrepancies with a note regarding section b and c. These discrepancies are associated with ESSER III and not ESSER II. The lack of documentation is due to employee turnover. Locating documentation was a challenge for the ESSER Reporting. We are currently reviewing the FY24 reports and making corrections. The corrected ESSER Recipient Data Collection Form will be updated and refiled during the Year 4 re-open period on 7/28/2025. Documentation will be centrally located in the common drive clearly marked. The review process will be well documented with completed sign-off documentation to confirm reconciliation between the GMS system and NH First, the financial system of record.

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Finding 540637 (2024-013)

Material Weakness 2024

State of New Hampshire

NH

Reporting Subrecipient Monitoring Material Weakness § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund - FFATA State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report ...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund - FFATA State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-013; 2023-008; 2022-013, 2022-016; 2021-013, 2021-015 - FFATA Reporting Anticipated Completion Date: 06/30/2025 Corrective Action Planned: The NHED concurs with this finding. The FFATA reporting procedure was redefined last year with updates to the GMS system implemented. GMS was updated to issue the GAN upon initial allocation instead of upon first approval of activities in the system. There were a few grants where the initial allocation was uploaded into GMS in 2021 with the first approval of activities completed after the GMS update. The GAN for these few grants was not created due to the change in procedure. Through the reconciliation process, these issues were identified and GANs were created later than anticipated. Moving forward, this will not be an issue as this was a limited transition period.

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Finding 540636 (2024-012)

Material Weakness 2024

State of New Hampshire

NH

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Material Weakness § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.029 Coronavirus Capital Project Funds State Agency: Department of Business and Economic Affairs (BEA) Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livef...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.029 Coronavirus Capital Project Funds State Agency: Department of Business and Economic Affairs (BEA) Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livefree.nh.gov Audit Report Reference: 2024-012 and 2023-006 - Reporting Anticipated Completion Date: No Later than 6/30/2025 Corrective Action Planned: In response to a similar finding in the 2023 audit, the Department modified reporting procedures to strengthen the precision of the reconciliation of reporting data to the Capital Project Fund dashboard. These changes were made prior to the end of the audit period but after the September 30th reporting cycle. Accordingly, the Department would note the application of audit procedures to the June 30, 2024, report did not identify similar errors. Regarding the tracking and reporting of actual total miles of fiber deployed and actual total locations; the Department would note Federal guidance documents state actual miles are not required to be reported until a project is completed. The “Coronavirus Capital Projects Fund: States, Territories, and Freely Associated States Project and Expenditure Report User Guide” (updated 12/20/2024) specifically instructs recipients to “Input the total miles of fiber planned to be deployed by the project” and “Provide the number of locations the project plans expect to serve”. Both of these instructions are accompanied by a notation stating actual amounts should be reported for projects marked as complete. The Department will take measures to ensure, upon project completion, reporting elements will be updated to reflect actual miles of fiber and locations served as per guidance. In doing so, and recognizing the unique characteristics of these reporting elements, the Department will take measures to obtain support sufficient to ensure the reported data elements are accurate. The Department is also taking measures during the active project period to review progress and expenditure allowability at project milestones, ensuring sufficient support and project progress.

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Finding 540635 (2024-011)

Significant Deficiency 2024

State of New Hampshire

NH

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.331

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.027 Coronavirus State and Local Fiscal Recovery Funds State Agency: NH Governor’s Office of Emergency Relief and Recovery Audit Contact: Michele Thibault Title: Director of Finance and Compliance Telephone: (603)-271-7951 E-mail ad...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.027 Coronavirus State and Local Fiscal Recovery Funds State Agency: NH Governor’s Office of Emergency Relief and Recovery Audit Contact: Michele Thibault Title: Director of Finance and Compliance Telephone: (603)-271-7951 E-mail address: Michele.Z.Thibault-G@goferr.nh.gov Audit Report Reference: 2024-011 – Procurement Anticipated Completion Date: April 30, 2025 View of Responsible Officials: The State’s vendor determination policy is consistently applied across all Department’s within the State. The State’s vendor determination policy does not identify or vary for subrecipient, beneficiary, or contractor payments, however, federal reporting requirements dictate stratification of subawards as defined within 2 CFR 200. Accordingly, state agencies utilize various methods to differentiate payments to subrecipients from payments made to beneficiaries or contractors. Although there may be requirements to stratify beneficiary payments from procurement contracts specific to individual program requirements, there is no unifying requirement for States to otherwise stratify these populations within uniform grant guidance codified within 2 CFR 200. For this reason sampling of payment data to differentiate beneficiaries from contractors can be difficult for test work purposes. As stated in 2 CFR 200.331, the State is responsible for making a case-by-case determination to determine whether the entity receiving federal funds is a subrecipient or a contractor. As such, the State has provided training and documentation to all Departments to utilize for determining if a program/project is for a subrecipient or contractor. While this determination will not impact the procurement process in the State, it does impact the monitoring process for subrecipients versus contractors and the State has followed the procedures to ensure the proper determination for oversight. Per 2 CFR section 200.303, the State has established and maintained effective internal control over federal awards to provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award by providing Departments training, information and processes for Departments to determine if federal funds are utilized for a subrecipient or contractor and how the use of those funds shall be monitored. The State will review the selections determined to be misclassified per 2 CFR 200.331 to evaluate their classification and where necessary make adjustments to considerations made in the application of the specified criteria of 200.331

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Finding 540634 (2024-010)

Significant Deficiency 2024

State of New Hampshire

NH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.027 Coronavirus State and Local Fiscal Recovery Funds State Agency: Department of Administrative Services (DAS) Audit Contact: Steven Giovinelli Title: Federal Grants and Cost Allocation Administrator Telephone: (603) 271-2278 E-mail...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.027 Coronavirus State and Local Fiscal Recovery Funds State Agency: Department of Administrative Services (DAS) Audit Contact: Steven Giovinelli Title: Federal Grants and Cost Allocation Administrator Telephone: (603) 271-2278 E-mail address: steven.giovinelli@das.nh.gov Audit Report Reference: 2024-010 - Suspension and Debarment Anticipated Completion Date: June 30, 2025 Corrective Action Planned: The Department concurs. Although the Department has procedures and internal controls in place designed to provide reasonable assurance the State complies with federal compliance requirements regarding suspension and debarment, the Department acknowledges the identification of noncompliance. Accordingly, the Department will review the existing system of controls to determine any potential adjustments to reduce the likelihood of future instances of noncompliance. The Department’s review will include consideration of inclusion of a suspension and debarment certification in all contracts regardless of funding source.CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.027 Coronavirus State and Local Fiscal Recovery Funds State Agency: Department of Business and Economic Affairs (BEA) Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livefree.nh.gov Audit Report Reference: 2024-010, 2023-004, 2022-009 - Suspension and Debarment Anticipated Completion Date: No Later than 6/30/2025 Corrective Action Planned: BEA partially concurs with the audit finding and has an anticipated completion date to the corrective action plan of June 30, 2025. BEA did review the suspension and debarment in SAM.gov, however, an acceptable validation record of such review was not maintained. To remedy the finding, BEA will ensure that documentation is maintained for the search of SAM.gov for suspension and debarment. Additionally, federal program contracts going forward will contain Exhibit F, Suspension & Debarment Certification, thereby satisfying said requirement. Condition: During KPMG testwork over suspension and debarment, they identified 3 BEA contracts with no supporting documentation that the BEA had verified either through a signed certification or searching SAM.gov that the entity was not suspended or debarred. Condition to be completed no later than 6/30/2025

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Finding 540631 (2024-009)

Material Weakness 2024

State of New Hampshire

NH

Subrecipient Monitoring Material Weakness Reporting § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278) State Agency: Department of Business and Economic Affairs Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Frederi...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278) State Agency: Department of Business and Economic Affairs Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livefree.nh.gov Audit Report Reference: 2024-009 - Reporting Anticipated Completion Date: No Later than 6/30/2025 Condition: Federal Financial Accountability and Transparency Act (FFATA) reports during the fiscal year ending June 30, 2024, were not filed in compliance with the Transparency Act related to WIOA programs. View of Responsible Officials: BEA concurs with the audit finding and has an anticipated completion date to the corrective action plan of June 30, 2025. Corrective Action Planned: BEA will evaluate polices & procedures as well as existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the reporting requirements in comparison to reports required to be filed versus filed and that all documentation used to support the data reported on the federal report(s) are properly maintained. Furthermore, BEA will enhance policies and procedures and re-implement to include internal controls ensuring all FFATA reports are submitted in compliance with the Transparency Act reporting requirements. BEA will ensure staff attends appropriate compliance trainings.

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Finding 540622 (2024-008)

Material Weakness 2024

State of New Hampshire

NH

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.306 § 200.414 § 200.434

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildli...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-008 - Matching Anticipated Completion Date: June 30, 2025 Corrective Action Planned: To have revised procedures in place to include additional documentation to ensure accuracy from the subrecipient. We concur with the finding; A. In-kind match documentation earned requires additional documentation to support subrecipient match contribution. Revised procedures will be implemented to include additional documentation from the subrecipient to ensure accuracy. B. Internal review of volunteer in-kind match calculations are in place, however, in one instance, prior year rates were used resulting in under reported in-kind match earned. The Department does review and track match received from the subrecipient. We do not agree there are questioned costs of $201,250.

View Audit 350389 Questioned Costs: $1

Finding 540621 (2024-007)

Material Weakness 2024

State of New Hampshire

NH

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.502

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildli...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-007 – Activities Allowed or Unallowed/Allowable Costs/Costs Principles Anticipated Completion Date: Unknown Corrective Action Planned: To have the ability to use NHFIRST for grant accounting in the future. Hopefully, the migration to CloudSuite will offer this option. We concur in part with the finding; A. The Department does recognize the NHFIRST system is the official financial system of the state of NH, however, at this time NHFIRST does not allow for us to be able to charge grants individually for staff working on grant funded projects through the NHFIRST system. Therefore, we use QuickBooks as a ‘calculator’ for these grant costs. The Department uses a calculated rate based on the employee’s pay rate, benefits and years of service. While it is an arduous and complicated task, there is currently no other option for capturing all costs of the employee to the programs. B. We do not concur with part B as we did supply the support to substantiate the payroll costs but it was not used for testing. C. We did provide a specific sample for testing but again not in the timeliness requested. The Department does perform reconciliations and pre-audits of information entered into QuickBooks to verify data is complete and accurate. Payment vouchers are entered into QuickBooks by the Federal Aid Accountant and verified by the Supervisor. The Supervisor also verifies payroll and Indirect. We do not agree there are questioned costs of $11,409.

View Audit 350389 Questioned Costs: $1

Finding 540620 (2024-006)

Material Weakness 2024

State of New Hampshire

NH

Reporting § 200.303 § 200.502 § 200.510

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildli...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-006 – SEFA Reporting Anticipated Completion Date: Completed Corrective Action Planned: Improved internal controls to evaluate amounts reported on the SEFA have been implemented. We concur in part with the finding: A. Out-of-period expenditure amounts were incorrectly included on the SEFA. These amounts have been identified and corrections have been made. B. Same as above. C. The Department partially concurs. For one grant, W108-L2 / F21AF04030, the amount understated is actually $5,431. As previously explained, a portion of the amount listed as understated, was a Donation to the purchase of property, and not a direct Department Expenditure. ($112.500.00). Corrections have been made to the SEFA. D. Only the total Federal share of expenditures were reported on the SEFA. The Department does perform reconciliations and pre-audits of information entered into QuickBooks to verify data is complete and accurate. Improved internal controls to evaluate the amounts reported on the SEFA have been implemented.

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Finding 540619 (2024-005)

Material Weakness 2024

State of New Hampshire

NH

Subrecipient Monitoring Cash Management § 200.303 § 200.332 § 200.501 § 200.521

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Randy Curtis Title: Federal Aid Administrator Telephone: (603) 271-0801 E-mail address: randy.l.curtis@wild...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Randy Curtis Title: Federal Aid Administrator Telephone: (603) 271-0801 E-mail address: randy.l.curtis@wildlife.nh.gov Audit Report Reference: 2024-005 – Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We partially concur with the finding. A. The Department concurs there were required elements missing from the information included in tested subaward agreements. The Department will develop templates and put in place a process to ensure that all subrecipient agreements contain all required communications. B. The Department concurs and has recently completed and is implementing new internal policies and procedures that address nearly all of the conditions identified in this finding overall. These written policies and procedures were designed to be in compliance with the requirements of 2 CFR Part 200 Subpart D - Subrecipient Monitoring and Management and to establish improved internal controls. The policy includes a process for completing a risk assessment which outlines they types and frequency of monitoring procedures and for documenting their completion. C. The Department partially concurs with this condition. We believe the level of detail included within the invoice was consistent with the terms of the agreements and project budgets and did allow Department staff reviewing the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. Additionally, the Department’s updated subrecipient monitoring policies and procedures will provide for testing and requesting detailed backup and support for at least one invoice annually. D. The Department concurs there was no specific evidence denoting approval of the subaward reports. However, Department project leaders do review reports received from subrecipients and typically include them as attachments in our own grant reports to the Fish and Wildlife Service. A step will be added to monitoring procedures to include specific Department approval of subrecipient reports. Further, the Department will include a step for documentation of the receipt and review of subrecipient Uniform Guidance audit reports.

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Finding 540618 (2024-004)

Material Weakness 2024

State of New Hampshire

NH

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: yin...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: ying.q.chen@DMAVS.nh.gov Audit Report Reference: 2024-004, 2023-003 – Cash Management Anticipated Completion Date: None Corrective Action Planned: Non Concur With regard to the segregation of duties, the SF-270 is a required form that DMAVS submits to the National Guard Appendix Program Manager for reimbursement with all back up documentation. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense on behalf of DMAVS to request the cash draw. Prior to the submission of reimbursement of any funds, each billing and invoice is reviewed, entered into a ledger and reconciled by three members of the accounting team. Once reconciled, the SF-270 is prepared and signed by the Financial Administrator. The SF-270 is then submitted to the appendix program manager for concurrence and then to the federal fiscal agent (USPFO) for approval. No funds are drawn down until approved by the USPFO. If this is not a satisfactory level of review, the department will request a new position to ensure that there the business function has the proper level of staffing to meet the requirements for segregation of duties.

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Finding 540617 (2024-003)

Material Weakness 2024

State of New Hampshire

NH

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: yin...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: ying.q.chen@DMAVS.nh.gov Audit Report Reference: 2024-003, 2023-002 – Reporting Anticipated Completion Date: None Corrective Action Planned: Non Concur This requires the Department to create a redundant manual ledger that duplicates the function of the current ledger and DTR. This is not an efficient use of time or personnel. DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all transactions that reconciles every month to NH First Detail Transaction Register (DTR), Federal Fund tracking sheet, and Federal reimbursement tracking sheet with backup documents. The tracking sheet for the federal register is not intended to account for the state share of billing. The state share is accurately accounted for in the DTR, the cumulative accounting in the SF-270 and associated back up documentation. Supporting documentation to substantiate the accuracy of lines a, c, e, and f is in the DTR, the cumulative accounting of each SF-270, the supporting documentation sent with the billing to the Federal Government, and Year-end Agency Report for Federal Awards. This includes reconciliation and analysis of SADB expenditures and revenues to the Statement of Appropriations by each Program Accounting Unit. The SF-270 form is continuous cumulative data that starts Oct 1st and runs through the end of that Federal Fiscal Year. The SF-270 is the required federal form DMAVS submits to the Federal National Guard Appendix Program Manager for reimbursement. Back up documentation is submitted with the SF-270. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense to affect the cash draw. DMAVS does not unilaterally make cash draws to the federal government. The USPFO, who is substantially involved provides an independent review and reconciles any discrepancies prior to approving any requests for reimbursement. One possible explanation for the finding is that the selected test works were not continuous, nor did they account for cumulative data.

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Finding 540613 (2024-002)

Material Weakness 2024

State of New Hampshire

NH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.1 § 200.303

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 10.553/10.555/10.556/10.559 Child Nutrition Cluster State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Refer...

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 10.553/10.555/10.556/10.559 Child Nutrition Cluster State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-002 - Child Nutrition Cluster Finding Anticipated Completion Date: June 30, 2025 Corrective Action Planned: The NHED concurs with this finding. NHED contacted the US Department of Agriculture (USDA) for information on FFATA reporting requirements for state education agencies. The contact at USDA, Suzanne Dagesse, responded on February 6, 2024, that they were not aware of the requirement, and that this requirement has never been communicated to the NHED Office of Food & Nutrition Programs, by USDA. NHED has had annual reviews conducted by USDA of the programs administered and this requirement has never been communicated. NHED will add the food and nutrition programs to the established FFATA process already implemented to ensure that amounts to subrecipients are tracked and that all first tier subawards of $30,000 or more are reported in accordance with FFATA.

View Audit 350389

Finding 540601 (2024-001)

Significant Deficiency 2024

Syracuse University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan Year-end June 30, 2024 The following finding was noted during the audit of Federal programs in accordance with 2 CFR 200. Management of Syracuse University agrees with the finding and proposes the following Corrective Action Plan. Finding Number 2024-001: Enrollment Reporting ...

Corrective Action Plan Year-end June 30, 2024 The following finding was noted during the audit of Federal programs in accordance with 2 CFR 200. Management of Syracuse University agrees with the finding and proposes the following Corrective Action Plan. Finding Number 2024-001: Enrollment Reporting Corrective Action Plan: The University has identified a remediation plan in response to the finding, including the following: 1. Immediate Mitigations (within 90 Days): a. The Office of the Registrar and Office of Financial Aid and Scholarship programs will formalize a quarterly check-in meeting with multiple levels of stakeholders to ensure that our enrollment reporting process is complying and to address any new concerns that may arise. These check-in meetings have been scheduled and begin on March 26, 2025. 2. Long-Term Mitigations (within 12 months) a. The Office of the Registrar will work with Information Technology Services colleagues to implement a Graduates Only Enrollment file for multi-career students to increase the quantity of records that can be automatically processed. This work will be made productional by February 1, 2026 i. This will reduce our error rate and decrease the volume of records requiring manual review, allowing for more focused attention on the most complicated scenarios. Responsible individuals: Michele B Sipley, Executive Director of Financial Aid Kelly Campbell, University Registrar

View Audit 350372

Finding 540598 (2024-001)

Significant Deficiency 2024

The Trustees of Davidson College

NC

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

The correc􀆟ve ac􀆟on plan is as follows: Anna L. Stovall, with the assistance of the Registrar’s office, will review the status of graduated students during the first two weeks in June 2025, to ensure their effec􀆟ve graduate date is accurately reported. Further, those students who have informed David...

The correc􀆟ve ac􀆟on plan is as follows: Anna L. Stovall, with the assistance of the Registrar’s office, will review the status of graduated students during the first two weeks in June 2025, to ensure their effec􀆟ve graduate date is accurately reported. Further, those students who have informed Davidson College that they are on a leave of absence will also be reviewed in the coming weeks. It is an􀆟cipated that these ac􀆟vi􀆟es will be completed not later than June 30, 2025. These ac􀆟ons are in response to audit finding 2024-001.

View Audit 350366

Finding 540596 (2024-003)

Significant Deficiency 2024

Southern Oregon University

OR

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract p...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed on March 17, 2025 and documentation was retained to support the submission. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: March 2025

View Audit 350358

Finding 540593 (2024-001)

Significant Deficiency 2024

Southern Oregon University

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: Ther...

Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Records Specialist and University Registrar will be reviewing and revising policies and procedures related to enrollment reporting with the Clearinghouse data which then feeds into NSLDS. SOU will review calendar preparations, data collection, data submission and confirmation, error handling, file preparation documentation/instructions to identify breakdown in the process that lead to noncompliant reporting. SOU will increase monitoring of Clearinghouse data and also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Rose Reinhart, Interim Registrar Planned completion date for corrective action plan: June 2025

View Audit 350358

Finding 540536 (2024-006)

Significant Deficiency 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Reporting Subrecipient Monitoring Cash Management § 200.302 § 200.303

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effecti...

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Management Response Corrective Action: The Department understands the issues and is continuing to take corrective action to improve reporting. In the past the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. The Grants Unit will focus on procedures to ensure the reporting requirements are met. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager

View Audit 350283

Finding 540529 (2024-004)

Material Weakness 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Cash Management Internal Control / Segregation of Duties Reporting § 200.303

Recommendation We recommend the Department train its staff on the various aspects of financial grant management including the specific requirement of the grants for which the Department receives federal funding. We recommend that the reconciliation process over grants be well documented and closely ...

Recommendation We recommend the Department train its staff on the various aspects of financial grant management including the specific requirement of the grants for which the Department receives federal funding. We recommend that the reconciliation process over grants be well documented and closely monitored by management. We recommend the Department work closely with the FEMA to establish a going forward point for the reconciliation of grants and the Federal accounts receivable/payable balance. Management Response Corrective Action: We concur with this finding and the auditor's recommendation. The Department is working to perform a comprehensive reconciliation of all grants and complete any draw down requests for grant funding that has been expended but not drawn down. The initial completion of billing for all the older grants and projects is estimated to be by March 2025. In addition to the historical reconciliation, the finance team is working to ensure that current grant expenditures are drawn down on a monthly basis when possible. The historical grant reconciliation must be prepared and reviewed prior to submitting the draw requests. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary

View Audit 350283

Finding 540446 (2024-005)

Material Weakness 2024

Hawaii Pacific University

HI

Questioned Costs Cash Management § 200.303 § 200.305

The University has policies and procedures to ensure the review of expenditures charged to federal grants prior to draw downs. However, the University failed to identify a mistake in a journal entry which resulted in a duplicate expense posting to the grant until after the draw down request had been...

The University has policies and procedures to ensure the review of expenditures charged to federal grants prior to draw downs. However, the University failed to identify a mistake in a journal entry which resulted in a duplicate expense posting to the grant until after the draw down request had been made. Specifically, the University charged prepaid amortization to a grant fund, although the expenditure had already been fully recorded to the grant fund. This resulted in a duplicated expense posting, one for the actual payment of the expenditure, and a second for the expense amortization. The University discovered the mistake after the duplicated expense had been drawn down. To correct this error, the University initiated the process to reduce a subsequent draw for the grant to ensure that overall, the grant is not overdrawn. Management reviewed the conditions which contributed to this error and is establishing the following controls to address this error: 1. The University will incorporate an additional review step for any journal entries posted to federal grants. The Office of Sponsored Projects and Business Office management will sign off on any journal entries which are posted to federal grants prior to the posting taking place. 2. The Business Office will reinforce existing procedures to all accounting staff responsible for prepaid expense accounting to ensure that prepaid expense is not recorded to federal grant funds. 3. The Office of Sponsored Projects will adjust its review process and train staff to ensure thorough review of all activities impacting grants, including journal entries made by the Business Office, before authorizing drawdowns. Person(s) Responsible: Assistant Vice President of the Office of Sponsored Projects. Controller & Associate Vice President. Targeted Correction Date: June 30, 2025.

View Audit 350256 Questioned Costs: $1

Finding 540338 (2024-003)

Material Weakness 2024

Yolo County Transportation District

CA

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

2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims is...

2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims issues, pending grant amendments, and limited time, as noted in Finding 2024-002. Additionally, the increased complexity of federal grants following the pandemic required adjustments to allocation methods and financial reporting. To address these issues, staff has refined internal processes, including improving worksheets, enhancing review procedures, and consolidating grant data into a single summary sheet for better tracking. The 2024 FTA Triennial Review acknowledged these improvements, and the corrective action plan was considered sufficient, with recommendations to closely monitor grant activity and update the worksheets as necessary. Moving forward, staff will continue formalizing procedures for expense allocation, improve reconciliation processes, and ensure grant expenditures align with available funding. Grant tracking will provide a clearer overview of balances, deadlines, and remaining funds. The Finance department also adjusted its billing practices to reconcile expenses earlier in the reporting cycle, allowing sufficient time for review and claim adjustments. Regarding the overclaimed amounts of $183,548 and $175,143, staff will work with the FTA to determine whether repayment is required or if the funds can be applied to future eligible expenses. These efforts will strengthen compliance, improve accuracy in financial reporting, and overall grant management. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2025

View Audit 350214

Finding 539640 (2024-005)

Significant Deficiency 2024

Nbcc

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to d...

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to demonstrate this. However, the case manager neglected to exit the individual from HMIS during the previous audit period. This has been corrected. No services or funds were provided to this individual following their exit from the program. Our program has a good track record of data compliance and we expect this was an exception and not the rule. Program management will review and train staff again on data compliance during a weekly staff meeting, and will also counsel the involved staff member on the error to ensure there is no similar future error. xiv. Contact Person (s) Responsible for Corrective Action: Cassie Roach, Safe Parking Program Director, croach@sbnbcc.org Joel Goforth, Homeless Services Director, jgoforth@sbnbcc.org xv. Anticipated Completion Date: The anticipated completion date is April 30, 2025.

View Audit 350179

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