Corrective Action Plans

Finding 38039 (2022-006)

Significant Deficiency 2022

NV

Allowable Costs / Cost Principles Questioned Costs Cash Management § 200.303

Finding Number: 2022-006 ? Approval of Expense Reimbursement Submittals Corrective Action Plan: All expense reimbursements should be approved in writing. The findings occurred at a time when Academica Nevada was shorthanded. Since that time all open positions have been filled. Grant managers send...

Finding Number: 2022-006 ? Approval of Expense Reimbursement Submittals Corrective Action Plan: All expense reimbursements should be approved in writing. The findings occurred at a time when Academica Nevada was shorthanded. Since that time all open positions have been filled. Grant managers send a request for approval for reimbursement to the applicable school. Approval is in writing, typically via email, prior to the submittal of the reimbursement request. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2023

View Audit 32473

Finding 38035 (2022-005)

Significant Deficiency 2022

Somerset Academy of Las Vegas

NV

Reporting Questioned Costs Significant Deficiency § 200.303

Finding Number: 2021-002 and 2022-005 Review and Approval Of the Schedule of Expenditures Of Federal Awards (SEFA) Corrective Action Plan: In 2022, the management office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to ve...

Finding Number: 2021-002 and 2022-005 Review and Approval Of the Schedule of Expenditures Of Federal Awards (SEFA) Corrective Action Plan: In 2022, the management office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has increased staffing to realign staff responsibilities to reduce individual workloads and provide additional oversight and review. On a monthly basis, reconciliations will be performed on grant submissions and expenditures, and reviewed by the Controller, Director of Accounting, or CFO. The annual SEFA will be reviewed by the Director of Finance or CFO. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2023

View Audit 32473

Finding 38034 (2022-002)

Material Weakness 2022

Franklin County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Karla J. Bauman Contact Phone Number:765-647-4631 Views of Responsible Official: I concur with the finding. Description of Corrective Action Plan: Suspension & Debarment-The Commissioners approved a new process for all contracts bein...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Karla J. Bauman Contact Phone Number:765-647-4631 Views of Responsible Official: I concur with the finding. Description of Corrective Action Plan: Suspension & Debarment-The Commissioners approved a new process for all contracts being paid with Federal money over $25,000 that must occur before they will approve the contract for said services. The department head must get the certification from the Contractor. The commissioners have also approved the Franklin County Internal Control Manual for Grant Administration which addresses the necessary requirements for the Suspension & Debarment. Any department receiving grants on behalf of Franklin County will be required to certify to the Commissioners that they have read the internal control manual for grant administration and that they understand their responsibilities and will follow all required Federal, State and Local regulations. Completed June 28, 2023.

View Audit 30392

Finding 38026 (2022-001)

Significant Deficiency 2022

Fit Kids, Inc., Dba Champion Schools

AZ

Procurement, Suspension & Debarment Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

EMERGENCY CONNECTIVITY FUND PROGRAM REFERENCE: 2022-001 and 2022-002 CLIENT RESPONSE We concur with the condition. Individual responsible for implementation of corrective action plan: Jonathan Cahal, IT Director Corrective action plan: We will update the ECF asset inventory listing to include...

EMERGENCY CONNECTIVITY FUND PROGRAM REFERENCE: 2022-001 and 2022-002 CLIENT RESPONSE We concur with the condition. Individual responsible for implementation of corrective action plan: Jonathan Cahal, IT Director Corrective action plan: We will update the ECF asset inventory listing to include the names of the students receiving the devices, the date the device is/was provided and returned, or if the device is missing, lost, or damaged. With each student name listed we will have a link to the documentation supporting our assessment that the student had an unmet need. We will also verify the asset inventory listing includes all devices and equipment that were purchased with ECF monies and received. Lastly, for new grants that we apply for, more than one person will review the grant requirements, and we will reach out to grant personnel at other entities or contact our consultants and auditors to help ensure we have access to, and have considered all the necessary compliance requirements. . Estimated completion date: July 15, 2023.

View Audit 34699

Finding 38013 (2022-007)

Significant Deficiency 2022

City of Montebello

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.430

Staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary ba...

Staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping. Responsible Person: Kevin Saycocie Expected Implementation Date: 07/01/2023

View Audit 32131

Finding 38009 (2022-007)

Significant Deficiency 2022

Hodges University, Inc.

FL

Questioned Costs Reporting Significant Deficiency § 200.303

2022-007 Higher Education Emergency Relief Fund (HEERF) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

2022-007 Higher Education Emergency Relief Fund (HEERF) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Misunderstanding of correct way to handle the accounting of the HEERF. Action taken in response to finding: We have adjusted our policies and provided training to prevent future inaccuracies in reporting when dealing with special funding. Name(s) of the contact person(s) responsible for corrective action: Melissa Mitro Planned completion date for corrective action plan: Effective immediately.

View Audit 28916

Finding 37983 (2022-004)

Material Weakness 2022

City of Logansport

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

FINDING 2022-004 Person Responsible for Corrective Action: Duane Ullom Contact Phone Number: 574-739-1416 Views of Responsible Official: We concur with the finding. We feel the explanation provided in Finding 2022-001 error three, provides an adequate explanation as to the occurrence as reported in ...

FINDING 2022-004 Person Responsible for Corrective Action: Duane Ullom Contact Phone Number: 574-739-1416 Views of Responsible Official: We concur with the finding. We feel the explanation provided in Finding 2022-001 error three, provides an adequate explanation as to the occurrence as reported in the Condition and Context. To address the Reporting issue the Clerk Treasurer and Deputy Clerk Treasurer will both check for the accuracy of the P & E report prepared by the Grant Administrator and initial the paper report form to establish documentation for future audits and to confirm the accuracy of the report for submission. Anticipated Completion Date: August 2023

View Audit 28480

Finding 37982 (2022-003)

Material Weakness 2022

City of Logansport

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-003 Person Responsible for Corrective Action: Duane Ullom Contact Phone Number: 574-739-1416 Views of Responsible Official: We concur with the finding. The city now understands the need for the verification of vendors. In the future the city?s Grant clerk will be assigned to vet all con...

FINDING 2022-003 Person Responsible for Corrective Action: Duane Ullom Contact Phone Number: 574-739-1416 Views of Responsible Official: We concur with the finding. The city now understands the need for the verification of vendors. In the future the city?s Grant clerk will be assigned to vet all contractors involved in federally awarded funds. The Clerk Treasurer will verify the list presented against contracts approved by the city with said contractors. Anticipated Completion Date: August 2023

View Audit 28480

Finding 37916 (2022-005)

Material Weakness 2022

Paris Union School District No. 95

IL

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One...

Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Plan: The District will appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Anticipated Date of Completion: Immediately upon learning of issue Name of Contact Person: Dr. Jeremy Larson, Superintendent

View Audit 33929 Questioned Costs: $1

Finding 37848 (2022-001)

Significant Deficiency 2022

Troy City Board of Education

AL

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

Corrective Action Plan The Troy City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings ...

Corrective Action Plan The Troy City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 Activities Allowed/Allowable Costs & Costs Principles (Payroll) Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? We recommend a more detailed and frequent review of the payroll register used to prepare the time and effort certifications should be performed and documented Action Taken: All late hires will be manually added to the review list as needed during the fiscal year for review. Tricia Norman, CSFO, will be responsible for the corrective action plan and anticipates completion of corrective action will be taken before 9/30/2023.

View Audit 33158

Finding 37797 (2022-105)

Material Weakness 2022

Maricopa County Community College District

AZ

Eligibility Questioned Costs § 200.303

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO ? Student Support Services 84.047 TRIO ? Upward Bound Award numbers and years: P042A200873, September 1, 2020 through August 31, 2025 P042A201342, September 1, 2020 through August 31, 2025 P042A200859, September 1, 202...

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO ? Student Support Services 84.047 TRIO ? Upward Bound Award numbers and years: P042A200873, September 1, 2020 through August 31, 2025 P042A201342, September 1, 2020 through August 31, 2025 P042A200859, September 1, 2020 through August 31, 2025 P047A171009, September 1, 2017 through August 31, 2022 P047A171082, September 1, 2017 through August 31, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $14,678 Name of contact persons: Kristina Winterstein, Associate Controller Anticipated completion date: December 31, 2023 The District is aware of the importance of maintaining effective internal control over its federal awards and ensuring compliance with applicable federal regulations. The District will review and, as necessary, revise current policies and procedures relating to student eligibility as it relates to the TRIO?Upward Bound programs as well as the policies and procedures relating to documenting the calculation and payment of student stipends to ensure compliance with applicable federal regulations. The District will enhance communication and training efforts to ensure records are maintained that demonstrate appropriate review and approval of student eligibility prior to awarding program services.

View Audit 29977 Questioned Costs: $1

Finding 37796 (2022-104)

Material Weakness 2022

Maricopa County Community College District

AZ

Reporting Questioned Costs 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

Questioned Costs Subrecipient Monitoring Material Weakness § 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 Questioned Costs § 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

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