Corrective Action Plans

The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time to allow the College to effectively close out the grant, or to obtain permission for funding of expenditures that will not be incurred/and or liquidated timely. Anticipated Completion Date: N/A Contact Person(s): Willie Noseep, Vice President for Administrative Services Coralina Daly, Vice President for Student Affairs

The organization will strengthen and document a formal process for documenting attendance. This process will include provide training to employees responsible for tracking attendance, implementing a signature sheet to be submitted and reviewed by program managers after each class, and incorporate review of attendance sheets into the payment processes for participant stipend payments ensuring only participants who correctly documented attendance are able to receive the stipend funds.

Reference Number: 2024-013 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Federal Transit Cluster Assistance Listing Number: 20.500, 20.507, 20.526 Award Number and Year: VT-04-0021-01 (3/14/2013 – 6/30/2016) Compliance Requirement: Cash Management, Period of Performance Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that VTrans review and enhance grant closeout procedures and internal controls to ensure that grants are closed out timely. We further recommend that VTrans review and enhance procedures and internal controls over cash management to ensure that cash draws are performed only against grants for which the period of performance has not expired. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The following factors contributed to the noncompliance: VTrans experienced staff turnover, at which point close out processes were missed in 2016. This resulted in a grant remaining with an open status in the TrAMS system well beyond the period of performance. During the 2024 review by program staff, a drawdown was inadvertently processed for this grant with the expired period of performance. At the time, VTrans lacked a formal, documented grant closeout process for FTA grants in the TrAMS system. Additionally, there was a breakdown in communication between the Accounts Receivable (AR) team and the Public Transit Program team regarding period of performance eligibility prior to processing the draw. VTrans has taken the following steps to strengthen internal controls and prevent recurrence of this issue: 1. Formalized Closeout Procedures: VTrans has implemented a structured grant closeout process for the AOT Public Transit Program that clearly defines responsibilities, timelines, and verification steps to ensure all federal awards are closed timely and in compliance with FTA requirements. This process assigns specific tasks to designated staff members and ensures that no drawdowns occur after the period of performance has ended. 2. Annual Period of Performance Review: VTrans has established and documented an annual review process for FTA grant periods of performance. This review has been formally integrated into the Agency’s Public Transit cash management procedures, ensuring that grant end dates are proactively monitored, and necessary extensions or closeouts are addressed before expiration. 3. Enhanced Communication and Documentation: VTrans has updated the internal Excel file used to facilitate communication between the Public Transit Program team and the AR team. The file now includes a designated column for period of performance, ensuring that all drawdowns are reviewed for eligibility before processing. This is also addressed in an update to the Agency’s Public Transit cash management procedure memo. VTrans will coordinate with FTA to determine the appropriate resolution for these funds. Any necessary repayment or adjustments will be completed in accordance with FTA guidance. At this time, FTA has not requested the funds be returned. Scheduled Completion Date of Correction Action Plan: All corrective actions will be implemented as of March 1, 2025. Contacts for Corrective Action Plan: Ross MacDonald, Public Transit Director ross.macdonald@vermont.gov

Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Corrective Action Planned: The Sandwich Public Schools will implement the following procedures to ensure that the 120 liquidation finding doesn’t happen again. 1. We will make sure that all costs are liquidated within the 120 day window after the end of the grant period. 2. If we see we are approaching the 120 day limit on a certain expense, we will reach out to DESE to ask for an extension to the 120 day liquidation requirement. 3. We will add these procedures to our Federal Grant Manual so that all are aware of these requirements. Anticipated Completion Date: June 30, 2025 Contact: Michelle Austin, Director of Finance and Business Operations

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant guidance has been updated to ensure items with unique service dates are properly reviewed. Additionally, during the three-month liquidation period, a monthly review of all expenditures will be conducted to verify they are applied to the correct period of performance. These actions will strengthen oversight and ensure compliance with grant requirements. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Condition: During the audit, it was identified that $247,000 in federal funds were expended outside of the authorized period of performance for the Emergency Shelter Grant Program under the CARES Act. These expenditures were deemed unallowable by HUD and required repayment. The issue resulted from the lack of an effective monitoring system to track grant performance periods and ensure compliance with federal requirements. Planned Corrective Action: 1. Implement a Grant Period Monitoring System: The organization will establish a formal process for tracking the start and end dates of each grant’s period of performance, including automated alerts and internal checklists. 2. Strengthen Internal Controls: Develop procedures to ensure all expenses are reviewed and approved based on the grant’s performance period before payment or reimbursement/ 3. Staff Training: Provide mandatory annual training for fiscal and program staff on Uniform Guidance cost principles, compliance requirements, and federal reporting standards. 4. Pre-Audit Reconciliation: Conduct quarterly reconciliations of grant expenses to verify compliance with the authorized periods and allowable cost principles. 5. Documentation Submitted to HUD: The organization has submitted supporting documentation and justifications to HUD to validate the expenditures incurred outside the contractual performance period. These expenditures were related to payroll and operational costs within the same program operation. The entity awaits HUD’s determination and will comply with any final resolution or additional corrective guidance provided.

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

Finding: The FFR for the year ending October 31, 2022 did not accurately report unliquidated obligations to ensure complete and transparent financial reporting. Cause: MHC changed accountants and accounting software during 2022 and also moved from a cash basis to accrual basis for preparing the FFR. The total of Federal Expenditures in section 1 O of the FFR was correct but the Unliquidated Obligations line was not completed. Correction: A revised, corrected FFR was submitted in August 2024. Corrective Plan for Future Years: Subsequent FFRs have been prepared correctly. The accountant ensures that line 1 O.f. on the FFR reflects the payable balance as of October 31, 20xx for the grant.

2022-060 Higher Education Coordinating Commission Strenthen controls to ensure expenditures are not obligated beyond the period of performance Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA32218F30; 2018, AA32218G10; 2018 AA32218G30; 2018, AA32218G70; 2018 AA32218H90; 2018, AA32218F31; 2018 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,523 (known) Criteria: 20 CFR 683.110; 2 CFR 200.343 (2018) WIOA grants are available for expenditure by the State during the grant program year and the two succeeding program years. In addition, the State must liquidate all financial obligations incurred no later than 90 calendar days after the end date of the period of performance. We judgmentally selected for review expenditures recorded in fiscal year 2022 related to 2018 grant award whose period of performance ended June 30, 2021. Our review of the supporting documentation found there were 3 out of 13 items with expenditures that were outside the period of performance. Total question cost for these expenditures were $47,523. Per management, these errors were due to a change in personnel and trying to balance out the 2018 grant after the fact. We recommend department management review and revise controls to ensure expenditures are only obligated during the period of performance federally mandated dates. MANAGEMENT RESPONSE: We agree with this recommendation. The three errors pertaining to those expenditures that were outside the period of performance, were due to a change in personnel and trying to balance out the 2018 grant, after the fact. The HECC have addressed these issues by ensuring that all new accountants are fully trained in a timely manner. Also, HECC has implemented training for all current accounting staff in identifying what is an allowable cost within the period of performance. This training also included a review of proper close-out procedures for all grants. Anticipated Completion Date: June 30, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

Name of Auditee: Syracuse Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2022 CAP Prepared by: William Killory, Chief Financial Officer Phone: (315) 470-4330 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2022-003 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - Closeout of CFP grants and all related reports will be handled by the Comptroller and CFO on a going forward basis in a timely manner subsequent to the grant being fully expended. The Authority will also familiarize ourselves with the Capital Fund Guidebook to ensure reporting requirements are being met. (c) Planned implementation date of correct action - Completed by June 30, 2023

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021