Corrective Action Plans

Finding 37796 (2022-104)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Reporting Special Tests & Provisions § 200.303

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

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

View Audit 29977 Questioned Costs: $1

Finding 37783 (2022-103)

Material Weakness 2022

Maricopa County Community College District

AZ

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fed...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Annette Linders, District Director of Financial Aid Operations and Compliance Anticipated Completion Date: December 31, 2023 The Maricopa County Community College District understands the need to establish and maintain effective internal controls over federal awards to provide reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms and conditions. The District further understands the need to disburse a Student Financial Aid (SFA) credit balance directly to a student or parent as soon as possible, but no later than (a) 14 days after the balance was posted to the student?s account, if the credit balance occurred after the 1st day of class for the payment period, or (b) 14 days after the 1st day of class, if the credit balance occurred on or before the 1st day of class for the payment period. The District will enhance internal controls and monitor SFA office?s adherence to districtwide policies and procedures, to ensure systemwide compliance with SFA credit balance requirements. The District office will expand staff training and communication efforts; optimize District and college collaborations; and monitor each college?s completion of the Unapplied Credits Report to ensure the timely processing of SFA credits.

View Audit 29977

Finding 37782 (2022-102)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fede...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Annette Linders, District Director of Financial Aid Operations and Compliance Anticipated Completion Date: December 31, 2023 The Maricopa County Community College District understands the need to establish and maintain effective internal controls over federal awards to provide reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms and conditions. The District further understands the need to reconcile direct loan institutional student records with direct loan disbursement records submitted to and accepted by the COD system in order to meet fiduciary responsibilities. The District will enhance internal controls and expand its current process for monitoring Student Financial Aid (SFA) offices? adherence to districtwide policies and procedures, to ensure systemwide compliance with Direct Loan program requirements. The District will enhance staff training and communication efforts; optimize District and college collaborations; provide a centralized location for completed reconciliations; and monitor each college?s submission to ensure Direct Loans are reconciled and reviewed each month on a timely basis.

View Audit 29977 Questioned Costs: $1

Finding 37781 (2022-101)

Material Weakness 2022

Maricopa County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fed...

Cluster Name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program-Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Year: July 1, 2021 through June 30, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Special tests and provisions Questioned Costs: Unknown Name of Contact Persons: Annette Linders, District Director of Financial Aid Operations and Compliance Anticipated Completion Date: December 31, 2023 The Maricopa County Community College District understands the importance of reporting accurate student enrollment statuses and all student enrollment status changes to the National Student Loan Database (NSLDS) for the Pell and Direct Loan programs within 60 days. The District will continue to monitor its Student Financial Aid (SFA) offices? adherence to Districtwide policies and procedures and enhance internal controls to ensure SFA office?s timely review, verification, and corrections to identified data prior to submitting the data to the NSLDS. District and college collaborations are being optimized; training and communications with emphasis on timeliness and completeness continue to be enhanced; and a centralized repository of enrollment reporting resources has been prepared and made available to staff.

View Audit 29977 Questioned Costs: $1

Finding 37774 (2022-025)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

Corrective Action Plan: To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446

Finding 37772 (2022-023)

Significant Deficiency 2022

State of Vermont

VT

Questioned Costs Subrecipient Monitoring Reporting § 200.303

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

Corrective Action Plan: To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446 Questioned Costs: $1

Finding 37771 (2022-022)

Significant Deficiency 2022

State of Vermont

VT

Questioned Costs Reporting Cash Management § 200.302 § 200.303

Corrective Action Plan: We will be implementing a new process that is more automated to ensure accuracy and timeliness of our CMIA draws. We have created a new draw sheet that will be more easily loaded and will be reconciled a couple times a year. The Deputy CFO or person assigned by the Deputy C...

Corrective Action Plan: We will be implementing a new process that is more automated to ensure accuracy and timeliness of our CMIA draws. We have created a new draw sheet that will be more easily loaded and will be reconciled a couple times a year. The Deputy CFO or person assigned by the Deputy CFO will perform a reconciliation at least two times a year, with the first reconciliation being done before the end of FY 2023. We are currently using the new form and plan to be doing our draws in compliance with CMIA by 4/1/2023. We are also keeping all the backup for the draw electronically to allow for the review to be done more easily. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: April 1st, 2023

View Audit 30446 Questioned Costs: $1

Finding 37769 (2022-021)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring Reporting § 200.303 § 200.332

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

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

View Audit 30446

Finding 37768 (2022-020)

Significant Deficiency 2022

State of Vermont

VT

Allowable Costs / Cost Principles § 200.303 § 200.430

Corrective Action Plan: The Agency of Administration Financial Services Division recognizes the need for a refresher training for all staff on existing procedures to minimize keystroke errors in the future. This training will be completed by May 31, 2023. An additional process will be added to th...

Corrective Action Plan: The Agency of Administration Financial Services Division recognizes the need for a refresher training for all staff on existing procedures to minimize keystroke errors in the future. This training will be completed by May 31, 2023. An additional process will be added to the existing procedures. On a quarterly basis, the General Ledger will be reviewed by program staff to check for reasonableness and the review will be confirmed by a Supervisor. Scheduled Completion Date of Corrective Action Plan: Expected: May 31, 2023: Training for FSD Staff on existing procedures Expected: June 30, 2023: Procedure for General Ledger Review implemented Contacts for Corrective Action Plan: Doug Farnham Deputy Secretary, Agency of Administration Douglas.Farnham@vermont.gov (802) 585-8119 Holly S. Anderson Chief Financial Officer, Agency of Administration ? Financial Services Division Holly.S.Anderson@vermont.gov (802) 505-1177

View Audit 30446

Finding 37766 (2022-019)

Significant Deficiency 2022

State of Vermont

VT

Cash Management § 200.303 § 200.305

Corrective Action Plan: To ensure accurate reporting and remittance of interest, the Agency shall implement the following steps: 1. Responsible staff will review; Uniform Guidance training resources on the U.S. Treasury website; ?Standards for Internal Control in the Federal Government? issued by t...

Corrective Action Plan: To ensure accurate reporting and remittance of interest, the Agency shall implement the following steps: 1. Responsible staff will review; Uniform Guidance training resources on the U.S. Treasury website; ?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); and training resources on the State of Vermont, Agency of Administration website. Status; completed. 2. Responsible staff will communicate with Vermont Treasury to ensure the interest accrued by HAF program funds are attributed to the HAF program and will be reflected on all reports sent to financial and program staff. Financial staff will set an automatic reminder in Vision to ensure interest is remitted per 2 CFR section 200.303(a). Status; completed. 3. Responsible staff will communicate with U.S. Treasury and U.S. Department of Health and Human Services regarding the unremitted interest and will remit the interest accrued above $500 for 2021 and 2022. Status: communication with U.S. Treasury and U.S. Department of Health and Human Services is initiated, estimated completion date March 31, 2023. 4. Responsible staff will review quarterly reports and ensure interest is being accrued and attributed to the HAF program. If interest is not accruing or any abnormalities are noted, program staff will communicate with financial staff and Vermont Treasury to address the issue. Status: completed and ongoing. 5. Upon receipt of the yearly report from financial staff, Responsible staff will request the annually accrued interest in excess of $500 be remitted to the U.S. Department of Health and Human Services per 2 CFR section 200.303(a) and any instructions issued by U.S. Treasury. Status: completed and ongoing. 6. Responsible staff will verify with financial staff that interest has been remitted. If any errors have occurred, program staff will communicate with the Supervisor and financial staff to address said errors and properly account for and remit the interest. Status: completed and ongoing. Scheduled Completion Date of Corrective Action Plan: Mach 31, 2023 Contacts for Corrective Action Plan: Maxwell Krieger, DHCD General Counsel maxwell.krieger@vermont.gov Naomi Cunningham, Housing Program Administrator naomi.cunningham@vermont.gov Chris Banning, ACCD Administrative Services Director IV christopher.baning@vermont.gov Tracy Badeau, ACCD Financial Director I tracy.badeu@vermont.gov

View Audit 30446

Finding 37765 (2022-018)

Significant Deficiency 2022

State of Vermont

VT

Reporting Subrecipient Monitoring § 200.303 § 200.502

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

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

View Audit 30446

Finding 37764 (2022-024)

Significant Deficiency 2022

State of Vermont

VT

Questioned Costs Cash Management § 200.303 § 200.514

Corrective Action: Vermont Department of Labor: The department is reviewing its process, procedures, and internal controls to ensure that all federal draws are being processed in their respective timeframes and in accordance with the stated CMIA funding techniques. The interest rate error occur...

Corrective Action: Vermont Department of Labor: The department is reviewing its process, procedures, and internal controls to ensure that all federal draws are being processed in their respective timeframes and in accordance with the stated CMIA funding techniques. The interest rate error occurred on one of our federal award?s interest calculations because the annual rate was used instead of the daily rate. We have since included a hyperlink to the postings of the federal rates in our procedures to ensure that we are using the correct rate. This is checked and confirmed quarterly during reconciliation. The federal awards where drawing was happening outside of our CMIA funding technique were Special Budget Requests (SBRs) that the Department received during the Covid pandemic. Unlike other federal awards each one of these may have several components, e.g., PUA Admin, PUA Implementation, and PUA Fraud under one subgrant number in the Payment Management System. We do not always get the NOAs in a timely manner and must reach out to the federal grant manager when there has been an increase in any of these grants to discover what these additional funds are for. As an example: to date we have 36 grant modifications on the umbrella grant number UI-34746-20-55-A-50. In the review of the Department?s process, procedures and internal controls we will put in steps to be proactive in requesting NOAs from US DOL Region 1. Agency of Education: AOE will be implementing a new process that is more automated to ensure accuracy and timeliness of our CMIA draws. We have created a new draw sheet that will be more easily loaded and will be reconciled a couple times a year. The Deputy CFO or person assigned by the Deputy CFO will perform a reconciliation at least two times a year, with the first reconciliation being done before the end of FY 2023. We are currently using the new form and plan to be doing our draws in compliance with the TSA by 4/1/2023. Agency of Administration: AOA will be implementing a new coversheet that will be required to be submitted alongside departments backup documentation when reporting their annual interest for CMIA. This require that each department with applicable programs complete one coversheet per program. The coversheet will have distinct fields for state liability, federal liability, and unclaimable liabilities to ensure that departments backup documentation is being properly translated when reporting to U.S. Treasury CMIA. The coversheet will use matching fields to the CMIAS portal to ensure not confusion when transferring information from departments into the portal. Scheduled Completion Date of Corrective Action Plan: DOL: 6/30/2023 AOE: 4/1/2023 AOA: 8/31/2023 Position Responsible for Implementation of Corrective Action: DOL: Name: Chad Wawrzyniak Position: Financial Manager Email: Chad.wawrzyniak.@vermont.gov AOE: Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 AOA: Name: Jordan Black-Deegan Position: Statewide Grants Administrator Email: Jordan.black-deegan@vermont.gov

View Audit 30446 Questioned Costs: $1

Finding 37757 (2022-017)

Significant Deficiency 2022

State of Vermont

VT

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

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

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

View Audit 30446

Finding 37756 (2022-016)

Significant Deficiency 2022

State of Vermont

VT

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

Corrective Action Plan: The Department will review its procedures and internal controls to ensure that there is documented proof of appropriate signoff prior to payment processing and charging of program costs. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Correct...

Corrective Action Plan: The Department will review its procedures and internal controls to ensure that there is documented proof of appropriate signoff prior to payment processing and charging of program costs. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37755 (2022-015)

Significant Deficiency 2022

State of Vermont

VT

Eligibility Special Tests & Provisions Significant Deficiency § 200.303

Corrective Action Plan: This finding was also found during the past two fiscal year?s Single Audit and is a carryover issue stemming from the same underlying problem. The RESEA Program has been in a state on ongoing transition coming out of the COVID-19 pandemic as the Department needed to close th...

Corrective Action Plan: This finding was also found during the past two fiscal year?s Single Audit and is a carryover issue stemming from the same underlying problem. The RESEA Program has been in a state on ongoing transition coming out of the COVID-19 pandemic as the Department needed to close the Program for a significant period during the pandemic and then subsequently transitioned to more of a virtual / flex program in calendar year 2021 and 2022. The Department has taken additional steps to try and correct this finding. For example, the Department instituted a mandatory check list for staff to complete as cases are closed. This was developed and provided to staff in June 2022. The RESEA supervisor continues to conduct random sampling on casefiles for accuracy reviews and will continue to provide ongoing supervisor feedback and staff training. Scheduled Completion Date of Corrective Action Plan: June 30 , 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37754 (2022-014)

Significant Deficiency 2022

State of Vermont

VT

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan: This finding identifies that the Department is not meeting the federal performance expectation for timely closure of BAM Paid Claims. The primary reason behind this performance deficiency is due to the limited federal administrative dollars provided to fund the administratio...

Corrective Action Plan: This finding identifies that the Department is not meeting the federal performance expectation for timely closure of BAM Paid Claims. The primary reason behind this performance deficiency is due to the limited federal administrative dollars provided to fund the administration of the UI Program. Because of the limited funds, the Department is forced to operate a minimal staffing level, which leads to the inability to ensure all work is conducted timely. Separately, this finding identifies that the Department did not provide signature signoff on two BAM casefiles pulled for review. The Department did maintain proper supervisor signoff in the USDOL SUN System where cases are formally managed. However, the Department was not able to produce the supervisor?s signoff on the paper copy maintained for audit purposes. The Department maintains an ongoing corrective action plan with the USDOL through the State Quality Service Plan (SQSP) for the performance of the BAM unit, including the timeliness of BAM case closure. For the supervisory review and documented signoff, the BAM Unit has created a new standard procedure to ensure that cases have the needed documentation. This standard procedure was shared with the staff via a unit meeting / training on February 28, 2023. Scheduled Completion Date of Corrective Action Plan: Complete Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37753 (2022-013)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Eligibility Material Weakness § 200.303

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

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

View Audit 30446

Finding 37752 (2022-012)

Material Weakness 2022

State of Vermont

VT

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

Corrective Action Plan: Prior to the onset of the COVID-19 pandemic, the Unemployment Insurance (UI) program was significantly underfunded by Congress and the USDOL leading to significantly reduced staffing levels. When the pandemic led to drastic increasing workload levels, the Department consciou...

Corrective Action Plan: Prior to the onset of the COVID-19 pandemic, the Unemployment Insurance (UI) program was significantly underfunded by Congress and the USDOL leading to significantly reduced staffing levels. When the pandemic led to drastic increasing workload levels, the Department consciously chose to prioritize ensuring that critical functions of the UI program were met and deprioritize other administrative aspects of the program, such as federal reporting. The Department continues to struggle with staffing challenges that have prevented the Department from cross training additional staff on these duties and having staff available to review and approve all USDOL required reports. The Department is currently working to implement organizational changes and implement policies and internal controls to address this issue. Scheduled Completion Date of Corrective Action Plan: December 31, 2023 Contacts for Corrective action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

View Audit 30446

Finding 37751 (2022-011)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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

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

View Audit 30446

Finding 37750 (2022-010)

Significant Deficiency 2022

State of Vermont

VT

Subrecipient Monitoring § 200.303 § 200.332 § 200.501

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

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

View Audit 30446

Finding 37749 (2022-009)

Significant Deficiency 2022

State of Vermont

VT

Cash Management Reporting Significant Deficiency § 200.303

The Department agrees with this finding and has implemented the following: ? Enhanced SF-271 policies and procedures to verify that detail line items agree with supporting documentation. The Department has improved its internal controls to ensure that SF-271 reports have been prepared accurately p...

The Department agrees with this finding and has implemented the following: ? Enhanced SF-271 policies and procedures to verify that detail line items agree with supporting documentation. The Department has improved its internal controls to ensure that SF-271 reports have been prepared accurately prior to submission and that the Federal share of reimbursement requests are calculated correctly. ? Distributed policies and procedures and trained staff to ensure understanding of the SF-271 process and federal reporting requirements. Completion Date: February 28, 2023 Summary Schedule of Prior Audit Findings: None Contact Person Responsible for Corrective Action: Kim Fedele, Financial Manager II

View Audit 30446

Finding 37736 (2022-008)

Significant Deficiency 2022

State of Vermont

VT

School Nutrition Programs Cash Management Reporting § 200.303

Corrective Action Plan: The Agency of Education?s new Child Nutrition grants management system, Harvest, now has the reports to back up the Federal FNS-10's built-in. In addition, Harvest now also retains a copy of each report created along with the backup for each report. Position Responsible ...

Corrective Action Plan: The Agency of Education?s new Child Nutrition grants management system, Harvest, now has the reports to back up the Federal FNS-10's built-in. In addition, Harvest now also retains a copy of each report created along with the backup for each report. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: April 1, 2023

View Audit 30446

Finding 37735 (2022-007)

Material Weakness 2022

State of Vermont

VT

School Nutrition Programs Equipment & Real Property Management Special Tests & Provisions § 200.303

Corrective Action Plan: The AOE CNP team will be implementing a new procedure starting 3/1/23, which adds an additional internal control (quarterly review by a Grants Program Manager) and outlines specific steps that the Grants Management Specialist and Grants Program Manager will take in the event...

Corrective Action Plan: The AOE CNP team will be implementing a new procedure starting 3/1/23, which adds an additional internal control (quarterly review by a Grants Program Manager) and outlines specific steps that the Grants Management Specialist and Grants Program Manager will take in the event that there is a discrepancy. Position Responsible for Implementation of Corrective Action Name: Conor Floyd Position: Grant Programs Manager, Child Nutrition Programs Email: conor.floyd@vermont.gov Phone Number: 802-828-0310 Date of Implementation of Corrective Action: 3/1/23

View Audit 30446

Finding 37734 (2022-006)

Material Weakness 2022

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

Corrective Action Plan: To address the accuracy and timeliness of our entries into the FFATA system, we will use the USASPENDING.GOV website to assist us in reconciling what has been entered into the FFATA system. This will allow us to ensure that our grant ledgers agree with what is entered into FFATA. This will be a reconciliation completed at least quarterly (following SOV fiscal year quarters) and will be completed by the Deputy CFO or position assigned by the Deputy CFO. We will also implement a process that will have all the steps necessary for a grant award or an amendment to ensure it is posted properly within our internal files and the external systems. This will ensure that new awards and amendments get routed and entered in the FFATA system timely. Our finance team also attended a FFATA training on February 3, 2023 for additional training on the FFATA system. We will look into the Batch upload process which was described in that training. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy Chief Financial Officer Email: sean.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: First Reconciliation to be completed March/April 2023 Full Implementation June 1,2023

View Audit 30446

Finding 37654 (2022-003)

Significant Deficiency 2022

Cornell College

IA

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

2022-003 HEERF Reporting ? Assistance Listing No. 84.425E, 84.425F Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with aud...

2022-003 HEERF Reporting ? Assistance Listing No. 84.425E, 84.425F Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review their procedures around HEERF reporting and ensure someone is designated to review prior to uploading the reports. Name(s) of the contact person(s) responsible for corrective action: Kelly Flege Planned completion date for corrective action plan: update plan

View Audit 36236

Corrective Action Plans

Filters