The Connecticut Institute for the Blind, Inc.

Finding 2025-001 - Significant Deficiency in Internal Controls over Procurement and Noncompliance with Uniform Guidance Procurement Standards (Lack of Written Policy) Federal Programs: Congressional Directives and COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.493 and 21.027 Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of the Treasury Pass-Through Agencies: State of Connecticut Department of Developmental Services, State of Connecticut Department of Mental Health and Addiction Services, State of Connecticut Department of Children and Families, City of Middletown, Connecticut, and State of Connecticut Judicial Branch Award Identification Numbers and Award Period: 1 CE1HS52667-01-00 (9/30/23-9/29/26), 24DDS0049RD (7/1/24-6/30/25), 23MHA2061POS01 (7/1/24-6/30/25), 22MHA22ARPAR3 (3/3/21-12/31/24), 24MHA37ARPAR4 (3/3/21-12/31/24), 24DCF0293 (7/1/4-6/30/25), SLFRP0128 (VOCA) (7/1/24-6/30/25) and SLFRP0128 (CSSD) (1/1/2021-12/31/26) Criteria or Specific Requirement The Code of Federal Regulations (CFR) Section 200.318(a) states that recipients must maintain and use documented procedures for procurement transactions under a federal award. These documented procurement procedures must be consistent with state, local and tribal laws and regulations and the standards identified in the CFR Sections 200.317 through 200.327. Condition For the period under audit, it was determined that Oak Hill did not have a formal, written procurement policy that complies with the Uniform Guidance regulations. While the entity followed purchasing practices, there was no documented procurement procedure manual outlining required purchasing methods (micro-purchase, small purchase, sealed bids), evaluation criteria, or conflict of interest requirements as required. Cause Oak Hill had not updated its internal policies to comply with the Uniform Guidance procurement standards. Effect or Potential Effect Oak Hill is not in compliance with procurement standards. Noncompliance with procurement standards could lead to questioned costs, and potential suspension or termination of federal awards. Questioned Costs There were no questioned costs identified. Context A written procurement policy that complies with the Uniform Guidance was not in place for the period under audit. Recommendation We recommend that Oak Hill develop, adopt and implement a written procurement policy that complies with the CFR Sections 200.317 through 200.327. Views of Responsible Officials A formal written procurement policy that complies with the Uniform Guidance regulations has been written. Based on internal practice, the policy will be presented to the policy committee in April 2026 for review and approval.

Finding 2024-001 Federal Program: Congressional Directives Assistance Listing Number: 93.493 Federal Agency: U.S. Department of Health and Human Services (subagency: Health Resources and Service Administration (HRSA)) Federal Award Identification Number: 1 CE1HS52667-01-00 (Award Date: 9/21/23) Criteria or Specific Requirement As per the Department of Health and Human Services, HRSA Notice of Award to the Organization and the Construction Projects (HRSA-23-117) Program Guidance document issued by HRSA, HRSA requires award recipients to seek prior approval through the Electronic Handbook for all pre-award costs. The Code of Federal Regulations, Section 200.458 defines pre-award costs as follows: costs that are incurred before the start date of the federal award or subaward directly pursuant to the negotiation and in anticipation of the federal award where such costs are necessary for efficient and timely performance of the scope of the work. These costs are allowable only to the extent that they would have been allowed if incurred after the start date of the federal award and only with written approval of the federal agency. Condition The Organization claimed pre-award costs under the award, which were determined to meet the criteria of the types of costs allowed under the federal award; however, such costs were not submitted to HRSA for prior approval and thus, prior approval was not obtained. Cause Due to turnover of the individuals responsible for overseeing the program, the new individuals involved did not recognize that the timing of the expenditure was prior to the start date of the federal award. Effect or Potential Effect HRSA may disallow the pre-award costs under the award. As per the Construction Projects (HRSA-23-117) Program Guidance document issued by HRSA, HRSA approval of pre-award costs is not guaranteed, and recipients incur pre-award costs at their own risk. Questioned Costs The pre-award costs incurred under the award that were not approved by HRSA are representative of known questioned costs and amount to $93,450 under Assistance Listing Number 93.493 and the federal award 1 CE1HS52667-01-00 (Award Date: 9/21/23). Context Total federal program expenditures were $108,401 and the pre-award costs claimed under the award totaled $93,450. Recommendation We recommend the Organization to strengthen internal controls over pre-award costs to ensure proper approval is obtained in accordance with the federal agency requirements. Views of Responsible Officials The Organization is in agreement with this audit finding. All grantor award guidelines will be reviewed by the Director of innovation & Grants and the Senior Director of Development to ensure all compliance requirements are interpreted and understood the same. If there is not a consistent understanding, then the Chief Development Officer will review the guidelines.

Finding No. 2021-001: Identification of the federal program: Federal Agency: U.S. Department of the Treasury, Federal Program: Coronavirus Relief Fund, CFDA/Assistance Listing 21.019, Pass-through Entities: State of Connecticut Department of Developmental Services, Department of Mental Health and Addiction Services, and Department of Social Services. Criteria - A sound system of internal controls incorporates appropriate supervisory review and approvals for transactions prior to entry into the trial balance. Supervisory reviews help to ensure transactions are complete, accurate and appropriately recorded. Condition - As a result of expenditure testing, there were instances where supervisory review was lacking, which included payroll time sheets and other payroll and stipend expense summary spreadsheets and certain non-payroll expense invoices. Cause - Transactions inadvertently bypassed the appropriate supervisory review and approval. Effect or potential effect - Expenditure transactions were recorded to the system of record, without appropriate supervisory review and approval. This could potentially cause transactions to not be appropriately recorded into the system of record and/or transactions to be recorded that were not allowable expenses under certain governmental programs. Questioned Costs - There were no questioned costs. Context - Appropriate supervisory review was lacking in transactions reviewed as part of the testing performed. Specifically, the following was noted: employee time sheets that lacked supervisory review and approval, a non-payroll expense that was miscoded to the wrong expense account, mathematical errors in other payroll expense summary spreadsheets and lack of support for two stipend payments. Recommendation - We recommend management review their current policies and procedures around supervisory reviews and make enhancements where necessary, to ensure these controls are operating effectively. Views of Responsible Officials - Oak Hill is in agreement with this audit finding. Oak Hill has implemented the following to address this finding: 1. Additional communications will be sent to all employees regarding Oak Hill's policy relating to approving time sheets weekly. 2. New technology systems are being implemented to control the submission and approvals of reimbursable expenses run through the payroll process. This new system will have required fields/approvals built into the process so the expense can not be paid without those required fields being populated. 3. Accounts payable is also expanding the use of our electronic invoice approving software which tracks approval electronically in a workflow process and will not allow invoices/expenses to be paid without proper authorization.