Corrective Action Plans

Finding 537437 (2024-001)

Material Weakness 2024

LA

Procurement, Suspension & Debarment

GRAMBLING HOUSING AUTHORITY 300 B.T. Woodard Circle Grambling, LA 71245 Phone No. (318) 247-6035 Fax No. (318) 247-6554 HOUSING AUTHORITY OF GRAMBLING, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2024 Corrective Action Plan Finding: Finding 2024-001- Capital Fund #14.872- Pr...

GRAMBLING HOUSING AUTHORITY 300 B.T. Woodard Circle Grambling, LA 71245 Phone No. (318) 247-6035 Fax No. (318) 247-6554 HOUSING AUTHORITY OF GRAMBLING, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2024 Corrective Action Plan Finding: Finding 2024-001- Capital Fund #14.872- Procurement and Special Tests Condition: (a)-The Authority should follow its procurement policy, which complies with state and federal regulations. Louisiana Revised Statute 39:1702, for required expenditures in excess of $5,000 but less than $15,000, requires quotes from at least three vendors by telephone, or in writing. Purchases in excess of $15,000 require more strict procedures, depending on the dollar amount. If an item(s) cost less than $5,000 but it is reasonable that the Authority will require more of the same item in the audit year, then three quotes are required. For example, assume the Authority purchases several refrigerators that total to $4,500. If it reasonable to assume that the Authority will need more than another $500 of refrigerator purchases in the audit year, then three quotes are needed on the initial purchase. (b)-Federal regulations require that monitoring of construction or rehabilitation-type expenses be documented in writing. Monitoring notes of construction progress, lack of progress, or issues such as contractor delay must be timely available and available to third parties. There are no required forms or format. Corrective Action Planned I am Sharon Dixon, Executive Director and Designated Person to answer this audit finding. We will comply with the auditor’s recommendation. Person responsible for corrective action: Sharon Dixson, Executive Director Telephone: (318) 247-6035 Housing Authority of Grambling, Louisiana Fax: (318) 247-6554 596 College Avenue Grambling, LA 71245 Anticipated Completion Date- September 30, 2025

View Audit 348637

Finding 537436 (2024-002)

Material Weakness 2024

Southwest Organizing Project

IL

Subrecipient Monitoring § 200.332

Finding No. 2024-002 21.027: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Name: Edith Robles Department: Finance Title: Director of Finance Anticipated Completion Date: June 30, 2025 Corrective Action Plan: An adequate subrecipient risk a...

Finding No. 2024-002 21.027: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Name: Edith Robles Department: Finance Title: Director of Finance Anticipated Completion Date: June 30, 2025 Corrective Action Plan: An adequate subrecipient risk assessment policy will be put in place to evaluate and monitor subrecipients. Southwest Organizing Project will provide subrecipients with all required Federal awards identifiers. Edith Robles will ensure that Federal award identifiers are included in subrecipients grant agreements.

View Audit 348633

Finding 537435 (2024-002)

Material Weakness 2024

Housing Authority of the City of Brownwood, Texas

TX

Questioned Costs Procurement, Suspension & Debarment

HOUSING AUTHORITY OF THE CITY OF BROWNWOOD, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 The Housing Authority of the City of Brownwood, Texas respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and Address of Independent Audit Firm: Urlaub & Co....

HOUSING AUTHORITY OF THE CITY OF BROWNWOOD, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 The Housing Authority of the City of Brownwood, Texas respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and Address of Independent Audit Firm: Urlaub & Co., PLLC P.O. Box 2663 Ada, OK 74821 Audit Period: June 30, 2024 The finding from the June 30, 2024 schedule of findings and questioned costs are discussed below: SECTION II – Financial Statement Findings 2024-001 Procurement Response: The Authority will review our procurement policy as well as the guidance obtained when we attended the procurement training conference. We will specifically review the appropriate times that tasks must be consolidated into a single procurement action. We will include in the bid proposals the conditions, material types, and specifications for the bid. We will document all procurement transactions. We will maintain a formal bid tabulation form for all contracts procured. We will request assistance from our Board of Commissioners to review bids and to prepare the bid tabulation for formal bids over $50,000. Contact Person: David Long, Executive Director Anticipated Date of Completion: June, 2025 SECTION III – Federal Award Findings and Questioned Costs U.S. Department of Housing and Urban Development 14.872 – Public Housing Capital Fund 2024-002 Procurement Response: See the response in Finding 2024-001.

View Audit 348623 Questioned Costs: $1

Finding 537433 (2024-005)

Significant Deficiency 2024

Little Eagle Grant School

SD

Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Contact Person – Pedro Rosa, Business Manager Corrective Action Plan –Management recommends all school personnel follow the purchase order process when making any purchases with school funding, as established by the School Board. Management has also started the practice of scanning all purchase docu...

Contact Person – Pedro Rosa, Business Manager Corrective Action Plan –Management recommends all school personnel follow the purchase order process when making any purchases with school funding, as established by the School Board. Management has also started the practice of scanning all purchase documents onto every purchase transaction in order to eliminate the possibility of lost or misplaced documents. Completion Date – 06/30/2025

View Audit 348621

Finding 537431 (2024-004)

Significant Deficiency 2024

Little Eagle Grant School

SD

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Contact Person – Pedro Rosa, Business Manager Corrective Action Plan – Management recommends the school purchasers and purchasing supervisors use IRS De Minimus standards for all gifts, including door prizes. Management also recommends school personnel get proper approval before making any purchases...

Contact Person – Pedro Rosa, Business Manager Corrective Action Plan – Management recommends the school purchasers and purchasing supervisors use IRS De Minimus standards for all gifts, including door prizes. Management also recommends school personnel get proper approval before making any purchases with school funding. Completion Date – 06/30/2025

View Audit 348621 Questioned Costs: $1

Finding 537424 (2024-006)

Material Weakness 2024

Blackford County Schools

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S42...

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass‐Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

View Audit 348618

Finding 537423 (2024-005)

Material Weakness 2024

Blackford County Schools

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.334 § 200.403

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and...

FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Allowable Activities Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425C, 84.425U Federal Award Numbers and Year (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: Agree Description of Corrective Action Plan: This was a singular occurrence where the rate for a remedial program was not approved by the BCS school board, and where the payments did not tie back to an allowable cost. This program and fund are no longer active. Anticipated Completion Date: Completed

View Audit 348618 Questioned Costs: $1

Finding 537415 (2024-004)

Material Weakness 2024

Blackford County Schools

IN

Procurement, Suspension & Debarment School Nutrition Programs § 200.303

FINDING 2024-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program ALN Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and ...

FINDING 2024-004 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program ALN Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY23, FY24 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Non-Compliance Contact Person Responsible for Corrective Action: Chad Yencer - Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: BCS has established the following internal controls to ensure compliance: 1. Internal Control: When a purchase is made at $10,000 or more using Federal Funds, the superintendent will require that any vendors selected are in compliance with the Procurement and Suspension and Debarment compliance requirement by completing one of the following quality checks with each vendor prior to purchase: a. Checking the federal System for Award Management (SAM) database at https://sam.gov/content/exclusions and maintain a screenshot of the search results. b. Collect a certification from the vendor directly c. Add a clause or condition to the covered transaction with the vendor In this audit, the Deputy Treasurer conducted the check but misspelled the vendors name while checking so no actual check was completed. Anticipated Completion Date: This corrective action will be implemented and completed immediately with any purchase made that meets the above threshold.

View Audit 348618

Finding 537414 (2024-003)

Material Weakness 2024

Blackford County Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

Finding 2024‐003 Subject: Child Nutrition Cluster – Allowable Costs/ Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Compl...

Finding 2024‐003 Subject: Child Nutrition Cluster – Allowable Costs/ Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Compliance Requirement: Allowable Costs/ Cost Principles Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Julie Dodd, Treasurer Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with the finding of the auditor Description of Corrective Action Plan: This was a singular occurrence in which indirect costs were applied in the wrong year. Moving forward, no indirect costs will be charged or paid outside of the correct time period for the fiscal year. Anticipated Completion Date: Completed

View Audit 348618 Questioned Costs: $1

Finding 537413 (2024-028)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEM...

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEMA-4474-DR-VT (2020), FEMA-4532-DR-VT (2020), FEMA-4621-DR-VT (2021), FEMA-4695-DR-VT (2023), FEMA-4720-DR-VT (2023) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should continue to improve its procedures and internal controls to ensure that all required subawards and subaward modifications are reported accurately and timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Public Safety will continue implementation of its corrective action plan from the prior year. A new procedure will be developed for a periodic review of FFATA entries to add a control step ensuring that all FFATA entries are timely and accurate. A training will also be delivered to Public Assistance staff to ensure that the FFATA entry process is understood in both FSRS and SAM.gov. These corrective actions will be completed by April 4th, 2025 Scheduled Completion Date of Corrective Action Plan: April 4, 2025 Contacts for Corrective Action Plan: Richard Hallenbeck, Director of Administration/Finance richard.hallenbeck@vermont.gov

View Audit 348596

Finding 537402 (2024-025)

Significant Deficiency 2024

State of Vermont

VT

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

Reference Number: 2024-025 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services (Agency) Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023)...

Reference Number: 2024-025 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services (Agency) Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023) 2405VT5MAP (10/1/2023 – 9/30/2024) Compliance Requirement: Special Tests and Provisions – Utilization Control Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls for Medicaid utilization control to ensure that cases are closed timely and that documentation of the results of reviews are maintained and communicated. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Special investigations Unit (SIU) only refers two types of cases to the Medicaid Fraud Residential Abuse Unit (MFRAU), these cases are: Personal Care Attendant (PCA) and provider fraud and abuse. Prior to 2021 most of those cases were kept in paper format. Since then, the SIU has fully transitioned to electronic files only. All PCA cases referred to MFRAU are assigned to the Duty Auditor (DA) of the Special Investigations Unit (SIU). The DA must send the case referral via a form that MFRAU must return with notification of acceptance or declination to investigate the allegation. If the case is accepted, then it remains under “open referred to MFRAU” status in our database and updates must be provided and documented by the DA during our MFRAU/SIU quarterly meetings until SIU receives a closure memo from MFRAU that documents the completion of their review. Additionally, all provider cases remain open with the auditor who investigated and referred the matter until a closing memo is received by the SIU. All documented follow ups are recorded in the case log. Scheduled Completion Date of Corrective Action Plan: This process has been implemented since 2021 for cases generated from that year forward. SIU Procedure Manual has been updated accordingly as of December 31, 2024. Contacts for Corrective Action Plan: Nadeth Fitzgerald, Director – SIU nadeth.fitzgerald@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537401 (2024-024)

Significant Deficiency 2024

State of Vermont

VT

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

Reference Number: 2024-024 Prior Year Finding: 2023-031; 2022-037; 2021-025; 2020-014; 2019-010 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Yea...

Reference Number: 2024-024 Prior Year Finding: 2023-031; 2022-037; 2021-025; 2020-014; 2019-010 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023) 2405VT5MAP (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions - Provider Health and Safety Standards Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency fully implement its CAP to ensure that documentation is maintained in accordance with program requirements and that all providers are compliant with required health and safety standards. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: All Letters of Good Standing as well as a Standard Operating Procedure to ensure continuation were implemented in April of 2022. Prior to April the process was manual and via telephone or email with the Tax Department. All Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to get a written notification from the Tax Commissioner. As of April 2022 all tax standing reviews are validated with a letter from the Vermont Tax department and documented in the Provider Management Module. Verification with the VT Tax Department of a provider’s tax standing has always occurred; However, the good standing verification was documented in the PMM system and the confirmation of the verification from the VT Tax Department was not consistently maintained in the PMM. Although the Agency has implemented its corrective action plan from a prior year audit, cases will still be identified under this CAP until the provider is due for their 5-year revalidation and successfully revalidates with VT Medicaid. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Deidra Jarvis, Member and Provider Services Supervisor deidra.Jarvis@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537400 (2024-023)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-023 Prior Year Finding: 2023-030; 2022-038; 2021-026 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/...

Reference Number: 2024-023 Prior Year Finding: 2023-030; 2022-038; 2021-026 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023) 2405VT5MAP (10/1/2023 – 9/30/2024) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency complete implementation of its prior year CAP to ensure that all required subawards and subaward modifications are reported timely to FSRS in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Agency of Human Services Internal Audit Group (AHS-IAG) is a designated centralized reporter of subawards for a Medicaid cluster (ALN 93.775, 93.777, 93.778) that is shared between all AHS departments. To address omissions and timeliness of subawards and subaward modifications reporting to FSRS, IAG conducted additional training tailored to each AHS Department to examine the results of FFATA testing conducted internally and reemphasized the FFATA compliance regulations. This ensured the Internal Audit Group (IAG) is provided with complete, accurate and timely subaward information for reporting in FSRS going forward. The context of the 2024 finding indicates that the departments understood the training materials and complied with the requirements to report. On at least an annual basis, IAG conducts a review of current federal rules and regulations pertaining to FFATA reporting for FSRS to assure the Agency’s procedures are up to-date. Coincidentally, IAG will also select a random sample of subawards and subawards modifications that meet the required threshold for FFATA reporting to ensure they are reported in FSRS system on a complete, accurate and timely basis. Scheduled Completion Date of Corrective Action Plan: March 31, 2025: Annual review of FFATA rules and regulations including subawards review. Contacts for Corrective Action Plan: Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537399 (2024-022)

Significant Deficiency 2024

State of Vermont

VT

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

Reference Number: 2024-022 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services (Agency) Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023)...

Reference Number: 2024-022 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services (Agency) Federal Program: Medicaid Cluster Assistance Listing Number: 93.775, 93.777, 93.778 Award Number and Year: 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls for Medicaid eligibility renewals to ensure that benefits for eligible participants are not discontinued. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The error was caused by a caseworker not following the steps within the job aid when processing eligibility for a late renewal form. Coverage closed on 9/30/24 for non-review. The renewal form was received on 10/17/2023 yet, coverage was reinstated for 11/1/2024 instead of 10/1/24. The gap in coverage was corrected on 9/16/2024 and coverage was backdated to 10/1/24. The eligibility unit notified the worker’s supervisor who reviewed the case error with the caseworker. In addition, eligibility staff receive refresher training yearly to review our business processes. The Eligibility Unit will continue to monitor cases through our internal QA process unit and through our off-year reviews conducted by the QC unit. Scheduled Completion Date of Corrective Action Plan: Coverage was corrected on September 16, 2024. Contacts for Corrective Action Plan: Nicole McAllister, Healthcare Assistant Administrator II nicole.mcallister@vermont.gov Sarah York, Healthcare Assistant Administrator I sarah.york@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537387 (2024-021)

Significant Deficiency 2024

State of Vermont

VT

Eligibility Student Financial Aid Subrecipient Monitoring § 200.303

Reference Number: 2024-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/202...

Reference Number: 2024-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it verifies U.S. citizenship for all participants and confirm that only eligible participants receive benefits under the program. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: This finding has been corrected as of January 2024 dating back to October 2023. The State is no longer pooling funding sources which means that we can identify cases by their true funding source. This means that only true CCDF cases will be audited going forward and family service cases (protective service) no longer follow CCDF rules including citizenship and identity. Scheduled Completion Date of Corrective Action Plan: December 31, 2024 Contacts for Corrective Action Plan: Karolyn Long, Operations Director karolyn.long@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537386 (2024-020)

Material Weakness 2024

State of Vermont

VT

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Reference Number: 2024-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/202...

Reference Number: 2024-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Special Tests and Provisions – Health and Safety Requirements Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance training monitoring procedures and controls to ensure that all child care providers complete required health and safety training. We further recommend that the Agency update its training content to ensure that it includes all required elements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Department for Children and Families-Child Development Division (DCF-CDD) licensing unit is in the process of rule revisions which will include all the required health and safety topics that must be covered within the first three months of employment. DCF-CDD licensing unit will be updating our monitoring checklists to ensure we are regulating to the federal standard. DCF-CDD licensing unit will conduct staff training that review the results of the SFY 2024 Single Audit and establish clear procedures for licensing staff to follow when monitoring licensed providers and their staff for ongoing professional development requirements. Scheduled Completion Date of Corrective Action Plan: DCF-CDD is currently in the rule revision process and have a goal to shepherd the rules through promulgation by December 31, 2025. DCF-CDD will update our monitoring checklists to align with the rule revision which will include a complete pre-service orientation training list that aligns with the federal standard. This will be completed by December 31, 2025. DCF-CDD will review the results of the SFY 2024 Single Audit with the licensing team on January 21, 2025. Licensing supervisors will begin reviewing annual site visit reports for the licensors they supervise to ensure CDD is monitoring for the required ongoing professional development trainings required beginning immediately. Contacts for Corrective Action Plan: Beth Maurer, Director of Child Care Licensing elizabeth.maurer@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537379 (2024-019)

Significant Deficiency 2024

State of Vermont

VT

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

Reference Number: 2024-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Award Number and Year: 2301VTTANF (10/1/2022 – 9/30/2023) 2...

Reference Number: 2024-019 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Award Number and Year: 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) Compliance Requirement: Reporting – ACF-199 Special Tests and Provisions – Penalty for Failure to Comply with Work Verification Plan Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it maintains adequate documentation, verification, and internal control procedures to ensure the accuracy of work participation rates reported in the ACF-199 reports. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: For the data system programming error finding, the Department removed the hard coding in the programming that limited participant hours to 40. This was completed as soon as the error was identified and our regional team approved the proposed corrective action. For the individual instances where the reported work participation rates reported on the ACF-199 report did not agree with supporting documentation and that supporting documentation contained errors or was incomplete, the Department will do the following: • Highlight each of the individual types of errors in our weekly newsletter that goes out to all staff and describe the correct action that should have been taken in documentation. • Have members of Reach Up Central Office (RUCO) team attend the Senior Benefits Program Specialist Sr. BPS) meeting to review the individual types of errors and describe the correct action that should have been taken. Sr. BPS are responsible for the direct training of district Benefits Program Specialists (BPS) that process eligibility. Following their meeting they will return to their district offices and provide an overview to the district eligibility staff. • RUCO will hold a virtual office hours session for eligibility staff to attend focused on the individual types of errors and the correct action that should have been taken. Scheduled Completion Date of Corrective Action Plan: • Data system programming error was corrected in October 2024. • Newsletter highlights will be shared with staff by January 31, 2025. • Sr BPS meeting will be attended by February 28, 2025. • Virtual office hours will be held by March 31, 2025. Contacts for Corrective Action Plan: Chris Dorer, Reach Up Assistant Administrator christine.dorer@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

View Audit 348596

Finding 537378 (2024-018)

Material Weakness 2024

State of Vermont

VT

Subrecipient Monitoring Material Weakness Reporting § 200.303

Reference Number: 2024-018 Prior Year Finding: 2023-024 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Hea...

Reference Number: 2024-018 Prior Year Finding: 2023-024 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Award Number and Year: NH75OT000034 (6/1/2021 – 5/31/2026) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency complete implementation of its prior year CAP to ensure that all required subawards and subaward modifications are reported timely to FSRS in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Financial Administrator will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “required for entry into the FSRS system” upon grant execution. The Financial Administrator and Manager will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the FSRS system by the last business day of each month. Please note that the scheduled completion date is 2/1/23 as the same FFATA reporting finding was identified for a different program during the SFY22 Single Audit, and the corrective action plan was applied across the Department as a whole. The FFATA issues identified in the SFY24 Single Audit pre-dated the implementation of the Health Department’s original corrective action plan. Scheduled Completion Date of Corrective Action Plan: February 1, 2023 Contacts for Corrective Action Plan: Lillian Smith, Financial Administrator lillian.smith@vermont.gov Jessica Brown, Financial Manager jessica.brown@vermont.gov Megan Hoke, Financial Director megan.hoke@vermont.gov Peter Moino, Director of Internal Audit peter.moino@vermont.gov

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Finding 537377 (2024-017)

Material Weakness 2024

State of Vermont

VT

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

Reference Number: 2024-017 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcar...

Reference Number: 2024-017 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Award Number and Year: NH75OT000034 (6/1/2021 – 5/31/2026) Compliance Requirement: Reporting – Performance Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that performance reports are accurate, agree with supporting documentation, and that supporting documentation is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Office of Health Equity Integration’s Director and Equity Manager will ensure that all supporting documentation are cross checked with formal submissions in CDC’s REDCap reporting system to verify consistency and accuracy of performance reports. Additionally, the Equity Manager and Program Administrator will confirm all supporting documentation are properly stored in the program’s SharePoint site by the end of each quarterly reporting period. Scheduled Completion Date of Corrective Action Plan: January 31, 2025 Contacts for Corrective Action Plan: Katherine Richardson, Program Administrator katherine.richardson@vermont.gov Ariel Carter, Equity Manager ariel.carter@vermont.gov Song Nguyen, Equity Director song.nguyen@vermont.gov Megan Hoke, Financial Director III megan.hoke@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

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Finding 537373 (2024-016)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-016 Prior Year Finding: 2023-018; 2022-029; 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Governor’s Emergency Education Relief Fund COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) C...

Reference Number: 2024-016 Prior Year Finding: 2023-018; 2022-029; 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: COVID-19 – Governor’s Emergency Education Relief Fund COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021 – Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) COVID-19 - American Rescue Plan – Elementary and Secondary School Emergency Relief –Homeless Children and Youth Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U, 84.425W Award Number and Year: S425C210009 (1/8/2021 – 9/30/2022) S425D210011 (1/5/2021 – 9/30/2022) S425R210033 (2/23/2021 – 9/30/2022) S425U210011 (3/24/2021 – 9/30/2023) S425W210047 (4/23/2021 – 9/30/2023) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior audit. It should review and enhance internal controls and procedures to ensure that all required subawards and subaward amendments are reported timely and accurately to FSRS no later than the end of the month following the month of issuance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency implemented a reconciliation process in March of 2023 that allows us to ensure our grant ledgers agree with what is entered into FFATA. The Agency will increase the number of reconciliations per year to quarterly. The Agency continues to work toward our preferred solution to address the accuracy and timeliness of our entries into the FFATA system by creating an upload file of the data from our grants management system. Scheduled Completion Date of Corrective Action Plan: July 1, 2025 Position Responsible for Implementation of Corrective Action Sean Cousino, Interim CFO sean.couisno@vermont.gov

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Finding 537372 (2024-015)

Significant Deficiency 2024

State of Vermont

VT

Cash Management Internal Control / Segregation of Duties § 200.303

Reference Number: 2024-015 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Student Support and Academic Enrichment Grants Assistance Listing Number: 84.424 Award Number and Year: S424A220047 (7/1/2022 – 9/30/2024) Compliance Requ...

Reference Number: 2024-015 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Student Support and Academic Enrichment Grants Assistance Listing Number: 84.424 Award Number and Year: S424A220047 (7/1/2022 – 9/30/2024) Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that the Agency review and enhance its internal controls to ensure that drawdowns are reviewed and approved in accordance with the Agency’s policies and procedures. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency will review its current Federal draw procedures and identify appropriate role assignment to ensure appropriate internal controls exist to allow for a separation of duties and dual control of critical process steps. Scheduled Completion Date of Corrective Action Plan: July 1, 2025 Position Responsible for Implementation of Corrective Action Sean Cousino, Interim CFO sean.couisno@vermont.gov

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Finding 537371 (2024-014)

Significant Deficiency 2024

State of Vermont

VT

Procurement, Suspension & Debarment § 200.219 § 200.303 § 200.324

Reference Number: 2024-014 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/3/2021 – 12/31/...

Reference Number: 2024-014 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/3/2021 – 12/31/2024) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that it maintains documentation that it competitively procures contracts and that it performs a cost analysis for all procurement actions in accordance with Agency of Administration Bulletin No. 3.5 and federal requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan The Agency of Administration has written and published Procurement and Contracting Procedures known as Bulletin 3.5. Section 9.3.14 (Documentation) details the required documentation that should be placed in the contract file. The Department of Buildings and General Services (a department of the Agency of Administration), Office of Purchasing and Contracting, is charged with maintaining procurement documentation on behalf of the Office of the Secretary of Administration. Department of Buildings and General Services, Office of Purchasing and Contracting, will conduct an internal staff re-training on Bulletin 3.5, Section 9.3.14. In addition, the Office of Purchasing and Contracting will perform an internal review for procurements completed by the Secretary’s office to ensure they are in compliance. Scheduled Completion Date of Corrective Action Plan: BGS OPC Staff Training – June 30, 2025 BGS OPC Internal Review – December 31, 2025 Contacts for Corrective Action Plan: Doug Farnham, Chief Recovery Officer douglas.farnham@vermont.gov Deb Damore, Director, Office of Purchasing and Contracting deborah.damore@vermont.gov

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Finding 537368 (2024-013)

Significant Deficiency 2024

State of Vermont

VT

Questioned Costs Cash Management Matching / Level of Effort / Earmarking § 200.303 § 200.343

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) Complianc...

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

View Audit 348596 Questioned Costs: $1

Finding 537367 (2024-012)

Significant Deficiency 2024

State of Vermont

VT

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

Reference Number: 2024-012 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Special Tes...

Reference Number: 2024-012 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance procedures and internal controls to ensure that it obtains weekly certified payrolls from all contractors. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Daily Work Reports (DWRs) submitted by the contractor concluded the outstanding punchlist items in June 2023, and in September 2023 a subcontractor submitted a DWR to AOT. The project went through Completion and Acceptance (C&A) in December 2023. The C&A process required confirmation that payrolls were received but did not include a final complete-verification step before project closeout. As a result, missing payroll certifications went unnoticed. Additionally, the Civil Rights team was unaware of the subcontractor’s work report since their review is triggered by certified payroll submissions, not DWRs. VTrans is updating the C&A checklist to require final confirmation that all certified payrolls have been received before project closeout, with coordination from the Civil Rights team if any are missing. This checklist is to be verified by both the Resident Engineer and the Regional Engineer. To further strengthen compliance, VTrans Construction will focus on education, and revise pre-construction meeting templates to emphasize that federal wage reporting requirements apply to all work on a project. Additionally, VTrans Civil Rights will reinforce these requirements in annual contractor training to ensure Prime and Subcontractors fully understand their payroll reporting responsibilities. VTrans will also remain cognizant of projects and DWRs submitted by new subcontractors and actively work to educate contractors at this point to prevent future payroll omissions. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of April 1, 2025. Contacts for Corrective Action Plan: Douglas Bonneau, VTrans Construction Engineer douglas.bonneau@vermont.gov

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Finding 537366 (2024-011)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting § 200.208 § 200.303 § 200.332 § 200.425 § 200.513

Reference Number: 2024-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Subrecipien...

Reference Number: 2024-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Missing Federal Award Date: The Contract Administration, Grants Unit addressed the deficiency of missing federal award dates during the FY23 State Single Audit (in effect as of 1/12/2024). As part of the updated award execution process, the Grants Unit now verifies that all awards include the federal award date and applicable FAIN number. Awards executed prior to the implementation of this process are being updated during amendments to ensure compliance. Subrecipient Monitoring: The root cause of the subrecipient monitoring deficiency was staffing shortages, which affected the Agency of Transportations (AOT) ability to meet monitoring requirements on time. The AOT monitoring requirements have been transitioned from the Audit Bureau to the Contract Administration, Grants Unit. The Grants Unit has already identified and will prioritize Subrecipients based on the last date monitored. Workflow modifications to include efficiencies are also in progress. These efficiencies will help with timeliness. The revisions to the monitoring activities will be in the VTrans Granting Plan effective July 1, 2025. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of July 1, 2025. Contacts for Corrective Action Plan: Tricia Scribner, Administrative Services Manager III tricia.scribner@vermont.gov

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