Corrective Action Plans

CSC?s management concurs with the finding. See Section IV- Current Year Corrective Action Plan.2022-002 Allowable Costs/ Cost Principles Name of Contact Person: Brenda Chandler and Johnny Mammen Corrective Actions: CSC has implemented a policy as of July 10, 2023, that ensures that personnel are hired after the positive background compliances confirmations are obtained along with the modification of internal controls to ensure CSC?s compliance with Federal statutes, regulations, and the terms and conditions of the federal award as stated in the grant requirements. The Human Resources Director will be responsible for implementing and monitoring this policy. Due to the new personnel in finance effective July 17, 2023, CSC will be able to ensure that all grants? receipts are supported by appropriate documentation for expenses incurred. The Senior Accountant will be supervised by the Director of Finance who will be responsible for the implementation of the corrective action. Proposed Completion Date: July 10, 2023 and July 17, 2023 Telephone Number: 202-517-6737

Finding 2022-006: Federal Financial Reporting Requirements (Significant Deficiency) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: Code of Federal Regulations (CFR) Section 200.303(b) requires non-federal entities to establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. CFR Section 200.510 states that the auditee must prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements which must include the total federal awards expended as determined in accordance with CFR Section 200.502. Condition: The schedule of expenditures of federal awards for the year ended December 31, 2022, did not originally include indirect costs totaling $43,632. Cause: FCE's management prepared the schedule of expenditures of federal awards using only direct costs. However, FCE had applied the 10-percent de minimis indirect cost rate when submitting its financial reports. Effect or Potential Effect: The exclusion of indirect costs caused inaccurate amounts to be reported in the SEFA at the start of the audit. This could have caused an inaccurate major program determination. Recommendation: FCE should implement a process for preparing the SEFA that includes comparing amounts reported in the SEFA to amounts included in financial reports of expenditures that are submitted to federal agencies. Action Taken: FCE acknowledges the importance of proper Federal Financial Reporting. FCE will develop and implement formal accounting policies and procedures to ensure that Federal Financial Requirements are met. These will include the steps to follow for preparation of the SEFA, including comparing amounts reported in the SEFA to amounts included in financial reports of expenditures that are submitted to Federal agencies.

Finding 2022-005: Cash Management and Reporting (Significant Deficiency) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.303 requires auditees to establish and maintain effective internal control over federal awards that provides 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: FCE did not maintain documentary evidence of the review and approval of either its requests for cash drawdowns or its performance reports in accordance with the internal control requirements. Cause: FCE's management team works collaboratively to prepare the requests for cash draw downs and prepare the performance reports prior to submission. Per discussion with management, the review and approval is performed verbally during this process. As a result, FCE was not able to provide adequate support to document the review and approval of either its requests for cash drawdowns or its performance reports. Effect or Potential Effect: FCE was not able to provide evidence of the implementation of internal controls related to review and approval for cash draw downs and performance reports. Therefore, these submissions may have been inaccurately prepared. Recommendation: FCE should retain documentary evidence of its review and approval process, which should occur prior to submission of the requests for cash draw downs and performance reports. Action Taken: FCE acknowledges the importance of documentation to support review and approval of cash drawdowns and performance reports. FCE will develop and implement formal accounting policies and procedures to ensure that it completes and maintains the proper documentation with respect to requests for an advance or reimbursement (Form SF-270) and filing a progress report (SF-PPR).

FINDING 2022-002 Contact Person Responsible for Corrective Action: Cynthia Barhydt Contact Phone Number: 260 627 5227 ext 1 Views of responsible Official: We concur with finding Description of Corrective Action Plan: I will check and sign off on any federal grant union wage payrolls before submitted for pay to federal grant department. Anticipated Completion Date: August 29, 2023

Finding Summary: For one employee tested, there was no formal documentation of a secondary review of the payroll allocation calculation. Responsible Individuals: Lisa Gochanour, Accounting Manager ? Stephanie Kilian, CFO Corrective Action Plan: Going forward the Accounting Manager will ensure that any payroll allocation changes have an appropriate status change form accompanying the change in payroll allocation. Any change in allocation lacking an approved status change form will be reported to the CFO who can work with the appropriate manager to secure the necessary documentation. All new employees will have the initial allocation documented on the status change form as part of the new hire process. Anticipated Completion Date: 08/01/2023 ? 12/31/2023

FINDING 2022-001 Contact Person Responsible for Corrective Action: Leslie Ellis Contact Phone Number: 812-244-2359 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: New procedures have been established to track and monitor all grants that the City receives. The Controller?s office will receive all grant documents (Funding Approval Agreements, Award Letters, etc.) from City Departments as grants are awarded. All grant documents will be reviewed to determine which grants are federal grants. When federal reimbursement requests or draws are made, the department will submit a copy to the Controller?s office. The Senior Financial Analyst in the Controller?s office tracks all grant receipts and disbursements. At the end of each year a grant worksheet will be sent to each department to complete with the year?s federal grant information. The Senior Financial Analyst will reconcile the worksheets to the Controller?s office records. Once reconciled, the Chief Deputy Controller will review the documents for approval. The Senior Financial Analyst will then enter the federal grant information into the Annual Financial Report in the State?s Gateway website. The Chief Deputy Controller will review and approve the information entered into Gateway. The Controller will perform a final review before the information is submitted and authorized in Gateway. Anticipated Completion Date: March 1, 2024

Northeast Indiana Works (NEINW) will continue to the use the established file review process. NEINW will be conducting a system wide WIOA file review. This review will be done in stages and will be completed by the end of May 2023. NEINW will deliver training to all staff to reacquaint them with the virtual service delivery model, including, but not limited, to the application process. This training will be conducted during the weekly Thursday morning training session on January 5, 2023. A follow up session will be held on January 12, 2023 to address any questions and to train staff who may have been absent during the January 5th session. Person(s) Responsible: NEINW President and CEO, CFO, Director of WorkOne Services and Director of Quality Initiatives Timing for Implementation: Staff training will be conducted in January 2023. System wide file review will be completed by the end of May 2023.

State Memorandum of Agreement Program for the Reimbursement of Technical Services ? ALN 21.113; U.S. Department of the Navy Cooperative Agreement #N40085-15-2-8711 Condition: Reports required by the federal program were not prepared and submitted timely and internal controls were not followed to ensure timely filing occurred. Planned Corrective Action: Tina M. O?Rourke, Business Manager, will ensure quarterly performance and financial reports are prepared and submitted 30 days following the end of each calendar quarter. Management?s Response: The Authority disagrees with this finding because periodic payment applications reflect the level of completion and outstanding for each budget line item. The Authority has implemented the recommendation for the year ending December 31, 2023. Individuals of the Authority management performing reporting will be aware of the requirements and follow established controls to ensure reports are prepared and submitted timely.

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN June 26, 2023 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2022-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the Project funds are only used for expenses of the Project. Additionally, we recommend the related entity reimburse the operating cash of the Project $2,000 for the accounting fees paid. Action Taken: Management acknowledges the Project funds were used for expenses of another entity. Management will ensure the related entity reimburses the operating cash of the Project $2,000 for the accounting fees paid and ensure that the Project funds are only used for expenses of the Project. Finding 2022-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2022-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting and financial procedures, system of internal controls and policies. FINDING - Federal Award Program Audit Finding 2022-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend that the Project continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Action Taken: Management acknowledges the Project funds were in excess of FDIC insured limits and will transfer funds to provide adequate FDIC insurance coverage for all cash accounts. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

Temporary Assistance for Needy Families (TANF) ? Assistance Listing No. 93.558 Recommendation: We recommend the County implement a process to ensure that errors identified in the TANF quality control review process are addressed in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is in isolated incident in our QA process. We have built a system with ticklers, and we missed this one. We will implement a secondary review by our QA supervisor to make sure all QA issues have been resolved in a timely manner. Name of the contact person responsible for corrective action: John McGraw ? Program Manager of Professional Standards Planned completion date for corrective action plan: July 1, 2024

2022-002 Material Weakness in Internal Control Finding: Internal Control over Reconciliation of Accounting Records Condition: The audit confirmation process did not go smoothly and resulted in confirmations being sent multiple times. Cause: The Accounting Manager did not have the adequate skills, knowledge, and experience to complete the audit confirmation process independently as previously believed to be the case by the Supervisor. Due to turnover in the accounting department, this was the first year for the Accounting Manager to send the confirmations independently. The Supervisor assessed that the Accounting Manager was ready to perform this task, however, this was not the case. Effect: The audit confirmation errors delayed the audit process. Additional oversight should have been provided to the Accounting manager. Response: Effective, August 1, 2023 or within 60 days of hire, the agency?s Accounting Manager shall receive training on the appropriate procedures for completing an audit confirmation. The Accounting Manager?s Supervisor shall review all confirmations for completeness prior to sending until such time it is determined that the Accounting Manager is able to perform this task independently.

Transitional Resources submits the following corrective action plan for the year ending December 31, 2022. Name and address of independent accounting firm: Lindley & Associates LLC, 1603 116th Ave NE, Suite 100, Bellevue, WA 98004-9003, Bellevue, WA 98004-9003 Audit period: January 1, 2022 to December 31, 2022 Contact person responsible for corrective action: Deb Orsillo, Director of Administration 2022-001: Material Weakness in Internal Control Finding: Internal Control over Timely Bank Reconciliations Condition: Transitional Resources? bank reconciliations were not completed in a timely manner. While supervisory personnel were aware the Accounting Manager was behind in accounting functions, they were unaware the bank reconciliations had not been completed in a timely manner. Cause: There was turnover in Transitional Resources? Accounting department which resulted in delays in completing the bank reconciliations. Due to the delay of the monthly accounting packets, which contain the bank reconciliations, Supervisory personnel did not initially identify those reconciliations were not completed in a timely manner. Effect: Safeguards of the agency?s accounts were in place by a thorough review of monthly bank statements by Supervisory personnel, however these reviews did not provide the same level of internal control as having timely bank reconciliations. Response: Effective June 26, 2023, bank reconciliations shall be prepared within 30 days of the receipt of the statement. The bank statement and bank reconciliation shall be reviewed by a person other than the preparer, initialed, and dated. The bank reconciliation balance shall agree with the general ledger balance. Both statements shall be initialed and dated as approved by supervisory personnel. In most cases, bank reconciliations shall be prepared by the Accounting Manager and reviewed by the Director of Administration. The Director of Administration shall not only ensure that monthly reviews of bank reconciliations are conducted but shall ensure all accounting information provided to the auditor is verified as complete, accurate, and timely.

AL Numbers: Various Program: Research and Development Cluster Corrective Action: All departments of the University will be reminded by the Central Accounting department that tagging is an integral part of the internal control process for capital assets. The Central Accounting team will send a memo to all equipment coordinators and Finance Managers at the campus units. The memo will be emailed by April 30, 2023. In addition, the Central Accounting team will schedule a virtual training to go over asset tagging procedures. All equipment coordinators will be invited to the training and it will be scheduled prior to June 30, 2023. Contact: Kathy Conrad and Maru Mendoza Expected Implementation: June 30, 2023

Corrective Action Plan: The Agency has submitted the Medical Loss Ratio report for the year ending 12/31/2021 no later than 12/31/2022. The report was delivered on 12/29/2022. Department of Vermont Health Access (DVHA) and the Agency of Human Services (AHS) have worked together over the past year to define the roles and responsibilities needed to deliver the Medical Loss Ratio (MLR) to AHS by the due date. AHS has agreed to provide Medicaid summaries, and once December enrollment is available, provide capitation rates multiplied by final enrollment for total calendar year expenditures. Additional to AHS deliverables, DVHA has updated its Standard Operating Procedures (SOP) to reflect the deliverables from AHS, additional detail to support each step in the process, and validation steps for AHS upon completion of the report by DVHA. The steps that have been added to the process allow for a more comprehensive review of the deliverable by both departments which will allow for an on-time delivery in its entirety by the due date of December 31. Scheduled Completion Date of Corrective Action Plan: December 29, 2022 Contacts for Corrective Action Plan: Patrick Rooney, DVHA Financial Director patrick.rooney@vermont.gov Allison Nowak, DVHA Financial Director allison.jensen@vermont.gov Tracy O?Connell, AHS-CO Financial Director tracy.oconnell@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan: Agency of Human Services Internal Audit Group (AHS-IAG) is a designated centralized reporter of subawards for a Medicaid cluster (AL No. 93.775, 93.777, 93.778) that is shared between all AHS departments. To address omissions and timeliness of subawards and subaward modifications reporting to FSRS, IAG will conduct additional training tailored to each AHS Department to examine the results of FFATA testing conducted internally, and reemphasize the FFATA compliance regulations. This will ensure the Internal Audit Group (IAG) is provided with complete, accurate and timely subaward information for reporting in FSRS going forward. Further, on at least an annual basis, IAG will conduct a review of current federal rules and regulations pertaining to FFATA reporting for FSRS to assure the Agency?s procedures are up-to-date. Coincidentally, IAG will also select a random sample of subawards and subawards modifications that meet the required threshold for FFATA reporting to ensure they are reported in FSRS system on a complete, accurate and timely basis. Scheduled Completion Date of Corrective Action Plan: Annual review of FFATA rules and regulations including subawards sample testing December 31, 2022 Individualized training for each AHS Department January 31, 2023 Contact for Corrective Action Plan: Peter Moino AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan 1. The corrective measures pertaining to DVHA?s enhanced oversight of Gainwell?s contractual obligation to DVHA to provide licensure validation service and documentation of active licensure will include established benchmarks for the overall improvement of the service, expansion of automated search services, progress reports and overall reduction of manual processes. By 5/1/2023 Gainwell will provide the DVHA Oversight & Monitoring Unit with Progress Reports that will be shared at the Fiscal Agent meeting and with DVHA Leadership to track progress and/or report roadblocks and escalate issues of any actual or potential failures to timely perform provider revalidations. Gainwell will use the Provider Management Module (PMM) and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiration date. Gainwell shall submit to DVHA on a weekly basis a list of providers who have been notified that they are due for re-validation and have not responded within 14 days of license expiration date. Gainwell will use PMM and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiring. The written detailed procedure for license updates will be finalized by 04/01/23 between the State and Gainwell and will include the following: a. Update the look forward period in the license screening service to 45 days. As a result, PMM will be updated automatically when the license screening service is available to locate an updated license. This configuration update will be in place by 04/01/23. For those licenses that the screening service is not able to locate an updated license, Gainwell will review and manually check for an updated license. If a new license is found, Gainwell will update accordingly. Gainwell will explore using Lexis Nexis as an additional service for manual review of license information and provide an update of potential solution by 03/17/23. If determined the Lexis Nexis solution is not viable, Gainwell will propose additional solution options by 05/01/23. b. Any provider whose license was not automatically updated as part of the screening service and could not be manually updated through the review process, an expiring license notification will be sent to the Mail-To contact information on file 30 days prior to their license expiration date. The expiring license notifications will be activated in PMM as of 04/01/23. Providers will be notified of this change in process as of 03/01/23 via banner. c. Gainwell will provide a weekly report of any providers whose license is set to expire in 14 days. This report will be delivered weekly beginning 04/17/23, two weeks after start date of license notifications. DVHA will work with Gainwell to finalize a process to address those providers listed. d. Gainwell will activate the termination job within the PMM that will automatically end a provider?s contract with VT Medicaid when no license was obtained through the process listed above by the license end date. This termination job will be activated on 06/05/23, two months after starting license notification. Notification to providers of this change in process will be sent no later than 05/01/23, via banner. Prior to the termination job being activated, Gainwell will continue to manually terminate when no updated license information is obtained, unless written exception is received from DVHA. All exception requests will be stored as part of the provider?s electronic record within PMM. By March 1st, 2023, Gainwell will provide the following information to DVHA: The databases, services, and available in state and out of state agencies Gainwell currently uses and plans to use in order to monitor and verify provider licenses and certifications; and 2. As of December 31, 2023, all revalidations will electronically reside in PMM. By December 31, 2023, All paper files, maintained prior to the implementation of the PMM, will be cataloged and sent to secure storage. To ensure all records are available for review, all application data is now being processed through PMM and available on demand. This includes paper application sent in by providers, Gainwell inputs the paper application into PMM. 3. The Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. At this time, the State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: 1. January 1, 2024 2. December 31, 2023 3. Completed Contacts for Corrective Action Plan: Suellen Bottiggi, DVHA Director of Member and Provider Services suellen.bottiggi@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan: 1. The corrective measures pertaining to DVHA?s enhanced oversight of Gainwell?s contractual obligation to DVHA to provide licensure validation service and documentation of active licensure will include established benchmarks for the overall improvement of the service, expansion of automated search services, progress reports and overall reduction of manual processes. By 5/1/2023 Gainwell will provide the DVHA Oversight & Monitoring Unit with Progress Reports that will be shared at the Fiscal Agent meeting and with DVHA Leadership to track progress and/or report roadblocks and escalate issues of any actual or potential failures to timely perform provider revalidations. Gainwell will use the Provider Management Module (PMM) and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiration date. Gainwell shall submit to DVHA on a weekly basis a list of providers who have been notified that they are due for re-validation and have not responded within 14 days of license expiration date. The written detailed procedure for license updates will be finalized by 04/01/23 between the State and Gainwell and will include the following: a. Update the look forward period in the license screening service to 45 days. As a result, PMM will be updated automatically when the license screening service is available to locate an updated license. This configuration update will be in place by 04/01/23. For those licenses that the screening service is not able to locate an updated license, Gainwell will review and manually check for an updated license. If a new license is found, Gainwell will update accordingly. Gainwell will explore using Lexis Nexis as an additional service for manual review of license information and provide an update of potential solution by 03/17/23. If determined the Lexis Nexis solution is not viable, Gainwell will propose additional solution options by 05/01/23. b. Any provider whose license was not automatically updated as part of the screening service and could not be manually updated through the review process, an expiring license notification will be sent to the Mail-To contact information on file 30 days prior to their license expiration date. The expiring license notifications will be activated in PMM as of 04/01/23. Providers will be notified of this change in process as of 03/01/23 via banner. c. Gainwell will provide a weekly report of any providers whose license is set to expire in 14 days. This report will be delivered weekly beginning 04/17/23, two weeks after start date of license notifications. DVHA will work with Gainwell to finalize a process to address those providers listed. d. Gainwell will activate the termination job within PMM that will automatically end a provider?s contract with VT Medicaid when no license was obtained through the process listed above by the license end date. This termination job will be activated on 06/05/23, two months after starting license notification. Notification to providers of this change in process will be sent no later than 05/01/23, via banner. Prior to the termination job being activated, Gainwell will continue to manually terminate when no updated license information is obtained, unless written exception is received from the DVHA. All exception requests will be stored as part of the provider?s electronic record within PMM. By March 1st, 2023, Gainwell will provide the following information to DVHA: The databases, services, and available in state and out of state agencies Gainwell currently uses and plans to use in order to monitor and verify provider licenses and certifications; and 2. To ensure all providers revalidate a minimum of every 5 years, PMM is automatically assigning the revalidation due date. Providers are notified 90 days prior to the due date and again at 45 days, if the provider does not revalidate by the due date, their contract is automatically terminated. At this time, all active providers are assigned a revalidation due date and every provider converted from the old system to PMM has a schedule that will result in revalidation of all legacy providers by December 31, 2023. Exception: If a provider?s revalidation application is returned to them, the provider has until their revalidation due date, or 30 days, whichever is greater, to correct and resubmit their revalidation. Example: Provider?s revalidation due date is 12/30/23 and their revalidation application is returned on 12/29/23. The provider will have until 01/29/24 to correct and resubmit. 3. The Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. At this time, the State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: 1. January 1, 2024 2. December 31, 2023 3. Completed Contacts for Corrective Action Plan: Suellen Bottiggi, DVHA Director of Member and Provider Services suellen.bottiggi@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan: ? One of sixty participants selected for testing turned 19 during the fiscal year. Due to the COVID-19 Public Health Emergency, states did not get authority to move customers from one MEC coverage group to another MEC coverage group until January 2021. The SoV began transitioning eligible age-off?s in March 2021. A report was created to capture anyone who had aged off since the start of the PHE. HC eligibility staff worked through the report to determine if customers were eligible to transition to another MEC coverage group. This individual was not captured on the report. They did not get transitioned until April 20, 2022 when the customer called and asked to be screened for Medicaid new adult. This case appears to be an isolated case and has since been corrected. ? For one of sixty participants, eligibility determination exceeded 45 days. Due to the COVID-19 Public Health Emergency, the SoV was accepting self-attestation for all income and resource verifications until November 1, 2021. In this case, the customer applied via the self-service portal and their MAGI-income verification line item (VLI) was pending. The SoV had reports in place at the time to pull all self-service applications with pending VLI?s to manually change them to verified. The SoV ran a report in October 2021 prior to the state resuming verifications for new applications to ensure all pending verification line items were verified and customers were enrolled timely. This appears to be an isolated case. Scheduled Completion Date of Corrective Action Plan: ? Age-off correction: April 20, 2022 ? Eligibility determination timeliness: September 15, 2021 Contacts for Corrective Action Plan: Nicole McAllister, DVHA-HAEEU HCAA II nicole.mcallister@vermont.gov Sarah York, DVHA-HAEEU HCAA I sarah.york@vermont.gov

Corrective Action Plan: The Child Development Division (CDD) has recently switched to a new IT system, Child Development Division Information System (CDDIS), that will check for the child?s IV-E eligibility and check to make sure that the child is in an eligible placement. With these checks it will allow the child to be marked as IV-E eligible or not and draw down the appropriate funding to match the eligibility. Scheduled Completion Date of Corrective Action Plan: July 31, 2023 Contacts for Corrective Action Plan: Karolyn Long ? Karolyn.Long@vermont.gov Emily Hazard ? Emily.Hazard@vermont.gov

Corrective Action Plan: The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as ?required for entry into the FSRS system? upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Scheduled Completion Date: 2/1/2023 Contacts for Corrective Action Plan: Jessica Brown, Financial Administrator, Vermont Department of Health Karen Clark, Financial Manager, Vermont Department of Health Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Corrective Action Plan ? Program Reporting: The Administrative Services Manager and the Public Health Preparedness Coordinator will create a central location for all supporting documentation to be stored and will ensure that the appropriate backup documentation is available for each progress report submitted to the CDC. The State Epidemiologist and PH Preparedness Coordinator will be responsible for ensuring that subject matter experts responsible for providing the information contained in progress reports are aware of the need to save supporting documentation. This supporting documentation will include ?point in time? reports from various electronic reporting systems as needed to ensure that data included in progress reports can be validated in the future. To ensure that progress reports are submitted timely the Public Health Preparedness Coordinator will verify that final copies of all program reports submitted are saved in a central location. The PH Preparedness Coordinator will also ensure that this supporting documentation includes a way to verify the date of report submission to the CDC. Corrective Action Plan ? Financial Reporting: The VDH Business Office will ensure that all financial reports are reviewed for accuracy prior to submission. The VDH business office will also continue to ensure that supporting documentation is available for all financial reports submitted, including date/time stamps recording timely submission. Scheduled Completion Date: 2/1/2023 Contacts for Corrective Action Plan: Patsy Kelso, State Epidemiologist, Vermont Department of Health Catherine Markesich, PH Preparedness Coordinator, Vermont Department of Health Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Corrective Action Plan: The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as ?required for entry into the FSRS system? upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Scheduled Completion Date: 2/1/2023 Contacts for Corrective Action Plan: Jessica Brown, Financial Administrator, Vermont Department of Health Karen Clark, Financial Manager, Vermont Department of Health Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Corrective Action Plan: VDH has updated its accounting structure and cost allocation plan to ensure that costs not otherwise eligible under federal grant awards are not attributed to the VDH administrative cost pool and allocated to federal grant programs. Scheduled Completion Date: 10/1/2022 Contacts for Corrective Action Plan: Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Corrective Action Plan: The AOE will require each participating independent school complete an inventory webform every two years for each piece of equipment that has been reimbursed or purchased by VTAOE for use by the independent school under CRRSAA. The Equipment will be tagged as property of the State of Vermont, and we will require a picture of the item for our records to ensure the item is in a good condition. We will maintain a list of equipment items including all that is required in 2 CFR section 200.313(d) (1). Our Administrative Services Director will add equipment and maintain our equipment list. Updates will be provided to this position by the EANS program team following the process below. The AOE EANS Program team will review each Equipment inventory submission for completeness including: the current condition and if the item is still being used for its intended purpose. Once the inventory is complete, the Program team will provide the inventory updates to the AOE Finance Team. As long as an independent school continues to use the equipment for an approved purpose, they will be asked to complete the inventory every two years. The Administrative Services Director will work with the State of Vermont?s Department of Buildings and General Services when equipment items need to be disposed of. We will provide them a list of the items and they will instruct us how to proceed. 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: 7/1/2023

Corrective Action Plan: The Agency will identify if a new ESEA Federal grant (or a grant based on an ESEA program) includes an Equitable Service requirement during the program completion of the ?New Grant Checklist?. If a new grant includes an Equitable Service requirement, the ESEA Equitable Service?s Ombudsman will be notified and will work with the grant program manager to ensure the build of the GMS application includes the correct level of detail and controls to meet the SEA requirements for oversight. When appropriate, the Agency will use its process for handling of Equitable Services associated with the Consolidated Federal Programs as models for determining the correct calculation method. The Agency will utilize built in business rules and internal controls within the Grants Management System (GMS) to gather the following information in the grant application for AOE review and approval prior to issuing a grant award agreement: 1. Calculation of the total proportionate share dollars an LEA must set aside for Equitable Services 2. Identification of Independent Schools participating in Equitable Services applicable to each LEA 3. Calculation of the dollars available for Equitable Services for each participating Independent School For each Federal grant that requires an equitable services component, the Agency will document the review and approval of the Equitable Services information through one of two processes prior to the grant award agreement: 1. A dedicated review assignment specific to equitable services, or 2. Verification statements on the review checklist for a general application reviewer Position Responsible for Implementation of Corrective Action: Anne Bordonaro, Division Director, Federal & Education Support Programs anne.bordonaro@vermont.gov 802-828-1388 Date of Implementation of Corrective Action: July 1, 2023