EIN: 030216254
UEI: Y2QDESVEDEK9
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (34 days from today).
What is a management decision? →A critical component of the analysis of internal controls over compliance is the quality control inspection form. During the assessment of Weatherization eligibility, the Quality Control Inspector (QCI) is a hallmark control serving as evidence of the job being ready for billing. Several jobs subject to monitoring by the Office of Economic Opportunity (OEO) were cited as having been improperly passed through the quality control process. Quality assurance visits by OEO identified multiple issues that should not have been passed through to finalization. These issues were of a nature that should have been identified and corrected prior to final approval had a proper QCI been performed. Despite these deficiencies, the units were approved and reported as complete. This indicates a breakdown in internal controls over the quality assurance process rather than an isolated error. Criteria or specific requirement: Each weatherization project will have a separate quality control inspection performed by an employee who is certified by the Building Performance Institute (BPI) as a QCI. Only homes that pass this QCI may be reported and invoiced to the State. A quality control inspection cannot be performed by a person who supervises the crew or by someone who has worked on the project. Quality control inspections performed by the QCI person, must at minimum include a final blower door test, final combustion appliance safety tests, final inspection of installed work and assurance that all work was done in compliance with the state of Vermont Weatherization Program Standards. If all is acceptable, the QCI shall acquire signature of client on QCI form. Cause: Lack of oversight by management - ineffective implementation of QCI procedures, including inadequate verification of work completion and insufficient supervisory review of QCI approvals. Questioned costs: No questioned costs were identified. Effect: The Organization approved and reported weatherization units that did not meet program requirements at the time of sign-off. This increases the risk that: noncompliant units are included in production reports, health and safety issues remain unaddressed, or costs associated with improperly approved units could be subject to disallowance upon monitoring or further review. Recommendation: We understand that ongoing cultural shifts have occurred in the weatherization department after the issues being identified by OEO. We recommend that the Organization reinforce QCI responsibilities and documentation standards to ensure that inspections are complete and in compliance with all federal and state requirements. In addition, the Organization can implement additional supervisory review of files before QCI is completed. As part of conversations with management, there was an increased emphasis on training – by providing refresher training to all QCI personnel throughout the year, this helps to ensure all requirements are met.
Show full finding ▾Hide full finding ▴U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Material Weakness in internal control over compliance 2025-001: Compliance Finding – Special Tests and Provisions Weatherization Assistance for Low-Income Persons (ALN 81.042) and Low-Income Home Energy Assistance (ALN 93.568) Condition: A critical component of the analysis of internal controls over compliance is the quality control inspection form. During the assessment of Weatherization eligibility, the Quality Control Inspector (QCI) is a hallmark control serving as evidence of the job being ready for billing. Several jobs subject to monitoring by the Office of Economic Opportunity (OEO) were cited as having been improperly passed through the quality control process. Quality assurance visits by OEO identified multiple issues that should not have been passed through to finalization. These issues were of a nature that should have been identified and corrected prior to final approval had a proper QCI been performed. Despite these deficiencies, the units were approved and reported as complete. This indicates a breakdown in internal controls over the quality assurance process rather than an isolated error. Criteria or specific requirement: Each weatherization project will have a separate quality control inspection performed by an employee who is certified by the Building Performance Institute (BPI) as a QCI. Only homes that pass this QCI may be reported and invoiced to the State. A quality control inspection cannot be performed by a person who supervises the crew or by someone who has worked on the project. Quality control inspections performed by the QCI person, must at minimum include a final blower door test, final combustion appliance safety tests, final inspection of installed work and assurance that all work was done in compliance with the state of Vermont Weatherization Program Standards. If all is acceptable, the QCI shall acquire signature of client on QCI form. Cause: Lack of oversight by management - ineffective implementation of QCI procedures, including inadequate verification of work completion and insufficient supervisory review of QCI approvals. Questioned costs: No questioned costs were identified. Effect: The Organization approved and reported weatherization units that did not meet program requirements at the time of sign-off. This increases the risk that: noncompliant units are included in production reports, health and safety issues remain unaddressed, or costs associated with improperly approved units could be subject to disallowance upon monitoring or further review. Recommendation: We understand that ongoing cultural shifts have occurred in the weatherization department after the issues being identified by OEO. We recommend that the Organization reinforce QCI responsibilities and documentation standards to ensure that inspections are complete and in compliance with all federal and state requirements. In addition, the Organization can implement additional supervisory review of files before QCI is completed. As part of conversations with management, there was an increased emphasis on training – by providing refresher training to all QCI personnel throughout the year, this helps to ensure all requirements are met.
Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Internal Control Over Compliance Views of Responsible Officials Management acknowledges the deficiency identified in the Quality Control Inspection (QCI) process. While questioned costs were not identified, we recognize that the breakdown in controls represents a material weakness requiring immediate and sustained corrective action. Since the Office of Economic Opportunity (OEO) monitoring review, the Organization has undergone structural and cultural changes within the Weatherization Department. Leadership has taken decisive steps to reinforce compliance expectations, supervisory accountability, and documentation integrity. Corrective Action Plan 1. Immediate Structural Oversight Enhancement • Will Eberle (Weatherization Director) is designated as the primary responsible official for QCI program compliance. • Scott Hall (Weatherization Associate Director and Quality Control Lead) is responsible for direct oversight of all QCI staff and inspection standards. • Chris Locarno (Business Manager) will provide executive-level oversight and ensure crossdepartmental accountability and reporting to senior leadership and the Board. Effective immediately: • No weatherization unit may be reported or invoiced until: o QCI documentation is fully complete, o All required test results (blower door, combustion safety, final inspection) are included, o Client signature is present, o Secondary supervisory review is completed. 2. Secondary File Review Control A new Two-Tier Review Process has been implemented: Tier 1 - QCI Review (Performed by Certified BPI QCI) • Full compliance with Vermont Weatherization Program Standards • Documentation of all required final tests • Verification that QCI was not performed by supervising crew members or project participant Tier 2 - Supervisory File Review • Conducted by Scott Hall • Random sampling at minimum 25% of completed units monthly • Monthly summary report submitted to Will Eberle • Quarterly compliance summary reviewed with Chris Locarno No unit will be considered production-complete until Tier 2 review confirms documentation sufficiency. 3. Mandatory QCI Refresher Training • All QC I-certified staff will complete refresher training on: o DOE and HHS requirements o Vermont Weatherization Program Standards o Documentation standards o Independence requirements • Training will occur semi-annually at minimum. • Scott Hall will document attendance and maintain training logs. • Chris Locarno will verify annual compliance training completion as part of management review. Additionally, peer case reviews will be incorporated quarterly to reinforce quality standards. 4. Cultural and Performance Accountability • QCI compliance metrics will be incorporated into staff performance evaluations. • Repeated documentation failures will result in retraining or removal of QCI approval authority. • Monthly compliance meetings led by Scott Hall will include trend review and corrective tracking. 5. Monitoring & Reporting Timeline Action Two-tier review implemented, Will Eberle, Completed Refresher training session, Scott Hall, Within 60 Days Executive compliance review structure , Chris Locarno, Completed Quarterly internal audit sampling, Scott Hall / Will Eberle, Ongoing Responsible Person: Scott Hall Date of Completion: April 1, 2026
A board roster was obtained for September 25, 2025, the final board meeting of the fiscal year. This listing showed that the board was comprised of 8 members of the following designations: participant sector – 4 members (44%), private sector – 4 members (44%), and public sector – 1 member (11%). Criteria or specific requirement: All eligible entities in the state of Vermont shall be governed by a tripartite board as described in section 6768 of "The Community Services Block Grant Act". The board must fully participate in the development, planning, implementation, and evaluation of the program to serve low-income communities, and must be composed of 1/3 elected public officials, at least 1/3 representative of lowincome individuals and families in the neighborhood served, and the remaining members of business or community groups. Cause: Lack of oversight by management. Effect: The Organization was out of compliance with CSBG statutory governance requirements for a portion of the fiscal year. Continued noncompliance may increase the risk of corrective action by the pass-through entity and jeopardize future CSBG funding. Questioned costs: No questioned costs were identified. Recommendation: Adopt a board composition matrix with term tracking. This matrix can include sector designation, term start and end dates, public official designation expiration, as applicable, and vacancy status. This matrix can be reviewed at each board meeting to ensure timely addressing any issues or concerns. Establish written requirement that vacancies must be filled within 60–90 days. Require immediate escalation to the board chair or governance committee if ratios fall below statutory minimums. This demonstrates proactive compliance rather than reactive correction. Document Contingency Procedures - Create procedures specific to the Organization for situations where: public officials decline appointment, democratic elections fail to produce candidates, and / or board size changes mid-year. Require Written Annual Certifications - Have the board chair or governance committee sign an annual certification confirming the tripartite composition compliance documentation of democratic selection procedures. This provides clear internal control and audit trail.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services State of Vermont Department for Children and Families 2025-002: Compliance Finding – Special Tests and Provisions Community Services Block Grant (ALN 93.569) Condition: A board roster was obtained for September 25, 2025, the final board meeting of the fiscal year. This listing showed that the board was comprised of 8 members of the following designations: participant sector – 4 members (44%), private sector – 4 members (44%), and public sector – 1 member (11%). Criteria or specific requirement: All eligible entities in the state of Vermont shall be governed by a tripartite board as described in section 6768 of "The Community Services Block Grant Act". The board must fully participate in the development, planning, implementation, and evaluation of the program to serve low-income communities, and must be composed of 1/3 elected public officials, at least 1/3 representative of lowincome individuals and families in the neighborhood served, and the remaining members of business or community groups. Cause: Lack of oversight by management. Effect: The Organization was out of compliance with CSBG statutory governance requirements for a portion of the fiscal year. Continued noncompliance may increase the risk of corrective action by the pass-through entity and jeopardize future CSBG funding. Questioned costs: No questioned costs were identified. Recommendation: Adopt a board composition matrix with term tracking. This matrix can include sector designation, term start and end dates, public official designation expiration, as applicable, and vacancy status. This matrix can be reviewed at each board meeting to ensure timely addressing any issues or concerns. Establish written requirement that vacancies must be filled within 60–90 days. Require immediate escalation to the board chair or governance committee if ratios fall below statutory minimums. This demonstrates proactive compliance rather than reactive correction. Document Contingency Procedures - Create procedures specific to the Organization for situations where: public officials decline appointment, democratic elections fail to produce candidates, and / or board size changes mid-year. Require Written Annual Certifications - Have the board chair or governance committee sign an annual certification confirming the tripartite composition compliance documentation of democratic selection procedures. This provides clear internal control and audit trail.
Community Services Block Grant (ALN 93.569) U.S. Department of Health and Human Services State of Vermont Department for Children and Families Finding 2025-002 Compliance Finding - Special Tests and Provisions Corrective Action Plan Board Composition Matrix In response to the audit comment concerning the need for a Board Composition Matrix, we reviewed our current Board Roster. This review indicates our Roster meets the requirements listed (sector designation, term start and end dates, public official designation expiration, as applicable, and vacancy status). The board is sent an updated roster upon request. and it is updated each time a board member and/or seat is changed. The Board Development and Governance Committee reviews this most of the months that they meet, especially when discussing board recruitment, which is an ongoing agenda item while a seat is vacant. Current Procedure Currently, the Board Chair (Abby White) and Governance Committee Chair (Karen Lowry Reed) are both regularly consulted about board vacancies by the Executive Director (Alison Calderara), both to commit to outreach, and to review current candidates for the board. The Board Bylaws currently reference that the Board Development & Governance Committee is responsible for "[filling] any vacancies on the Board as soon as reasonably Possible." Additionally, all Board members sign an acknowledgement of the Bylaws annually, which reference the board composition. Recruitment is the responsibility of the Development and Governance Committee. Proposed Update of Procedure With the assistance of associated staff, the Development & Governance Committee will create a procedure to follow when vacancies arise, that covers unforeseen vacancies, as well as planned ones (such as when a board member's term limit is approaching). This will also include reference for different sectors, each of which have slightly different requirements for coming on the board. Capstone will complete this written procedure within 90 days. Current Status The Board seat that resulted in the organizational standard finding was filled November 2025. Three of the four required public sector seats are now filled. Responsible Person: Alison Calderara Date of Completion: June 28, 2026
The Organization approved and provided Weatherization Assistance Program (WAP) services to a household located in a two-unit residential property. Based on a review of tenant income documentation, neither unit met the program’s income eligibility requirements at the time eligibility was determined. Despite this, the household was deemed eligible and weatherization services were performed and charged to the WAP grants. Criteria or specific requirement: For Department of Energy grants, one of the following criteria must be met within all multi-dwelling unit buildings 2(+) units in size regardless of if an individual building is part of a larger project or not: A. A minimum of 66% of the dwelling units within a multi-dwelling unit building must be occupied by a family/household that meets the income eligibility requirement, or B. A minimum of 50% of the dwelling units within duplexes, four-unit buildings and certain eligible types of large multi-family buildings must be occupied by a family that meets the income eligibility requirement, or C. The property meets the HUD based categorical eligibility requirements outlined within DOE’s WPN 22-5: Expansion of Client Eligibility in the Weatherization Assistance Program. Cause: Lack of oversight by management - The Organization did not adequately apply WAP eligibility requirements for multi-unit dwellings. Specifically, staff did not sufficiently verify and document income eligibility for each unit within the property prior to approving the dwelling for services. This indicates a breakdown in eligibility review controls and supervisory oversight for properties containing more than one unit. Effect: WAP funds were used to provide services to an ineligible property, resulting in unallowable program costs. This noncompliance increases the risk of questioned costs and potential repayment to the pass-through entity. Questioned costs: $4,048.39 Recommendation: We understand that ongoing cultural shifts have occurred in the weatherization department after the issues being identified by OEO. We recommend that the Organization strengthen eligibility determination procedures for multi-unit dwellings, including clear documentation requirements for each unit. Implementation of additional supervisory review of eligibility determinations for properties with more than one unit prior to service approval would be helpful. Providing targeted staff training on WAP income eligibility rules and treatment of multi-unit properties will continue to strengthen the team. Lastly, working with the pass-through entity to resolve questioned costs, including repayment if required.
Show full finding ▾Hide full finding ▴U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services 2025-003: Compliance finding – Eligibility Weatherization Assistance for Low-Income Persons (ALN 81.042) and Low-Income Home Energy Assistance (ALN 93.568) Condition: The Organization approved and provided Weatherization Assistance Program (WAP) services to a household located in a two-unit residential property. Based on a review of tenant income documentation, neither unit met the program’s income eligibility requirements at the time eligibility was determined. Despite this, the household was deemed eligible and weatherization services were performed and charged to the WAP grants. Criteria or specific requirement: For Department of Energy grants, one of the following criteria must be met within all multi-dwelling unit buildings 2(+) units in size regardless of if an individual building is part of a larger project or not: A. A minimum of 66% of the dwelling units within a multi-dwelling unit building must be occupied by a family/household that meets the income eligibility requirement, or B. A minimum of 50% of the dwelling units within duplexes, four-unit buildings and certain eligible types of large multi-family buildings must be occupied by a family that meets the income eligibility requirement, or C. The property meets the HUD based categorical eligibility requirements outlined within DOE’s WPN 22-5: Expansion of Client Eligibility in the Weatherization Assistance Program. Cause: Lack of oversight by management - The Organization did not adequately apply WAP eligibility requirements for multi-unit dwellings. Specifically, staff did not sufficiently verify and document income eligibility for each unit within the property prior to approving the dwelling for services. This indicates a breakdown in eligibility review controls and supervisory oversight for properties containing more than one unit. Effect: WAP funds were used to provide services to an ineligible property, resulting in unallowable program costs. This noncompliance increases the risk of questioned costs and potential repayment to the pass-through entity. Questioned costs: $4,048.39 Recommendation: We understand that ongoing cultural shifts have occurred in the weatherization department after the issues being identified by OEO. We recommend that the Organization strengthen eligibility determination procedures for multi-unit dwellings, including clear documentation requirements for each unit. Implementation of additional supervisory review of eligibility determinations for properties with more than one unit prior to service approval would be helpful. Providing targeted staff training on WAP income eligibility rules and treatment of multi-unit properties will continue to strengthen the team. Lastly, working with the pass-through entity to resolve questioned costs, including repayment if required.
Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management acknowledges the eligibility determination error involving a two-unit dwelling and agrees that eligibility verification procedures were not sufficiently applied in accordance with DOE requirements for multiunit properties. The Organization takes this finding seriously and is committed to strengthening controls to prevent recurrence. The Organization is actively working with the pass-through entity to resolve the questioned costs of $4,048.39 and will repay any disallowed costs as required. Corrective Action Plan 1. Multi-Unit Eligibility Control Protocol A new Multi-Unit Eligibility Determination Checklist has been implemented requiring: • Individual income verification for each unit • Calculation worksheet demonstrating compliance with: o 66% rule, OR o 50% rule (where applicable), OR o HUD categorical eligibility per WPN 22-5 • Written supervisory approval prior to job authorization No multi-unit property may proceed to audit or production until eligibility documentation is approved. 2. Pre-Service Supervisory Approval Requirement • All multi-unit eligibility determinations must be reviewed and signed by: o Will Eberle (Weatherization Director) • Documentation must be verified before work order issuance. This adds a preventive control prior to expenditure of funds. 3. Executive Oversight Review • Will Eberle (Weatherization Director) will receive a monthly eligibility compliance report. • Any exceptions will trigger immediate review. • Quarterly summary reporting will be presented to senior leadership. 4. Targeted Eligibility Training • Staff will complete focused training on: o DOE WAP multi-family eligibility requirements o Income documentation standards o HUD categorical eligibility • Training will be conducted within 45 days and annually thereafter. • Attendance logs and materials will be maintained by Scott Hall. 5. File Audit & Continuous Monitoring • Will Eberle (Weatherization Director) will conduct monthly random sampling of: o 100% of multi-unit approvals for the next 6 months o Minimum 20% thereafter • Findings will be documented and tracked. 6. Resolution of Questioned Costs • The Organization is in communication with the pass-through entity regarding the $4,048.39 in questioned costs. • Repayment will occur promptly if required. • A repayment tracking file will be maintained by finance and reviewed by Chris Locarno. Implementation Timeline Summary Action, Responsible Party, Completion Target: Multi-unit checklist implemented, Scott Hall, Completed Supervisory sign-off requirement, Scott Hall, Immediate Staff eligibility training, Scott Hall, Within 45 days Executive reporting framework, Chris Locarno Completed Monthly sampling audits, Will Eberle, Ongoig Resolution of questioned costs WX Finance / Chris Locarno, Within 90 days Statement of Commitment The Organization is committed to restoring and maintaining full compliance with all federal and state Weatherization program requirements. Leadership, including, but not limited to: Will Eberle (Weatherization Director), Scott Hall (Weatherization Associate Director), and Chris Locarno (Business Manager), has implemented structural safeguards, enhanced supervisory review, and reinforced a culture of compliance and accountability to ensure that these deficiencies do not recur. Management believes the corrective actions outlined above address both the immediate deficiencies and the underlying control weaknesses identified in the audit. Responsible Person: Will Eberle Date of Completion: April 1, 2026
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