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Audit of the Office of Justice Programs Victim 

Compensation Grants Awarded to the Vermont 

Center for Crime Victim Services, 

Waterbury, Vermont

AUDIT DIVISION

 20-091

AUGUST 2020
Executive Summary 

Audit of the Office of Justice Programs Victim Compensation Grants Awarded to the 

Vermont Center for Crime Victim Services, Waterbury, Vermont 

Objective 

The objective of the audit was to evaluate how the 

Vermont Center for Crime Victim Services (VCCVS) 

designed and implemented its crime victim 

compensation program. To accomplish this objective, 

we assessed performance in the following areas of grant 

management: (1) grant program planning and 

execution, (2) program requirements and performance 

reporting, and (3) grant financial management. 

Results in Brief 

As a result of our audit, we concluded that VCCVS used 

its Victims of Crime Act (VOCA) funding to enhance its 

crime victim compensation program. We did not take 

issue with VCCVS’s use of the administrative funding or 

drawdowns. 

However, we did find areas of improvement for VCCVS’s 

programmatic and financial management policies and 

procedures. 

Recommendations 

Our report contains five recommendations to the Office 

of Justice Programs (OJP) to assist VCCVS in improving 

its grant management. We requested a response to our 

draft audit report from VCCVS and OJP, which can be 

found in Appendix 2 and 3, respectively. Our analysis of 

those responses is included in Appendix 4. 

Audit Results 

The U.S. Department of Justice Office of the Inspector 

General completed an audit of two VOCA victim 

compensation formula grants awarded by OJP, Office for 

Victims of Crime (OVC), to VCCVS in Waterbury, 

Vermont. The OVC awarded these formula grants, 

totaling $393,000 in fiscal years 2016 and 2017, from 

the Crime Victims Fund to provide financial support 

through the payment of compensation benefits to crime 

victims throughout Vermont. As of February 2020, 

VCCVS drew down a cumulative amount of $392,416 for 

all of the grants we reviewed. 

Grant Program Planning and Execution – We 

determined that VCCVS had limited criteria authorizing 

payment of lost wages and loss of support. Additionally, 

VCCVS did not accurately calculate and report its Crime 

Victim Compensation State Certification Forms, resulting 

in less program funding provided by OJP than what 

should have been awarded to Vermont. 

We also found VCCVS’s standard of cooperation with law 

enforcement for victims of sexual assault was not 

documented, and it did not have policies and procedures 

to track data necessary to determine if a victim 

cooperated. As a result, VCCVS’s state certification and 

reimbursement requests included costs that may not 

have aligned with the purpose of the victim compensation 

program. 

Program Requirements and Performance 

Reporting – We determined that VCCVS complied with 

the performance reporting and award special conditions 

we tested. 

Grant Financial Management – We found payments 

were adequately supported and complied with the VOCA 

Guidelines and VCCVS policies, procedures, and 

guidelines. However, we determined that VCCVS did not 

design and implement federal grant accounting 

procedures in accordance with grant award 

requirements. Further, VCCVS did not have written 

policies and procedures necessary to ensure its Federal 

Financial Reports were accurate and supported. 

i 
AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM COMPENSATION GRANTS AWARDED TO 

THE VERMONT CENTER FOR CRIME VICTIM SERVICES, 

WATERBURY, VERMONT 

TABLE OF CONTENTS 

INTRODUCTION ............................................................................................ 1 

The Grantee........................................................................................ 2 

OIG Audit Approach ............................................................................. 2 

AUDIT RESULTS ........................................................................................... 3 

Grant Program Planning and Execution ................................................... 3 

Program Implementation ............................................................. 3 

Inadequate Lost Wages and Loss of Support Policies and Procedures.. 4 

Annual State Certification ............................................................ 5 

Program Requirements and Performance Reporting .................................. 7 

Annual Performance Reports ........................................................ 8 

Compliance with Special Conditions ............................................... 8 

Grant Financial Management ................................................................. 9 

Grant Expenditures ..................................................................... 9 

Grant Accounting...................................................................... 10 

Financial Reporting ................................................................... 11 

Drawdowns .............................................................................. 12 

CONCLUSION AND RECOMMENDATIONS ........................................................ 13 

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY .................................. 14 

APPENDIX 2: VERMONT CENTER FOR CRIME VICTIM SERVICES RESPONSE TO THE 

DRAFT AUDIT REPORT ........................................................................ 16 

APPENDIX 3: OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE DRAFT 

AUDIT REPORT.................................................................................. 19 

APPENDIX 4: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF 

ACTIONS NECESSARY TO CLOSE THE REPORT ....................................... 23 
 

 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM COMPENSATION GRANTS AWARDED TO 

THE VERMONT CENTER FOR CRIME VICTIM SERVICES, 

WATERBURY, VERMONT 

INTRODUCTION 

The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) 

completed an audit of two victim compensation formula grants awarded by the 

Office of Justice Programs (OJP), Office for Victims of Crime (OVC) to the Vermont 

Center for Crime Victim Services (VCCVS) in Waterbury, Vermont. OVC awards 

victim compensation grants annually from the Crime Victims Fund (CVF) to state 

administering agencies. As shown in Table 1, in fiscal years (FY) 2016 and 2017, 

these OVC grants totaled $393,000. 

Table 1 

Audited Grants 

Fiscal Years 2016 – 2017 

Award Number Award Date Award Period 

Start Date 

Award Period 

End Date Award Amount 

2016-VC-GX-0045 9/19/2016 10/1/2015 9/30/2019 $ 274,000 

2017-VC-GX-0044 9/28/2017 10/1/2016 9/30/2020 119,000 

Total: $ 393,000 

Note: Grant funds are available for the fiscal year of the award plus 3 additional fiscal years. 

Source: OJP 

Established by the Victims of Crime Act (VOCA) of 1984, the CVF is used to 

support crime victims through DOJ programs and state and local victim services.1 

The CVF is supported entirely by federal criminal fees, penalties, forfeited bail 

bonds, gifts, donations, and special assessments. The OVC annually distributes 

proceeds from the CVF to states and territories. VOCA victim compensation 

formula grant funds are available each year to states and territories for distribution 

to eligible recipients. 

The primary purpose of the victim compensation grant program is to 

compensate victims and survivors of criminal violence for: (1) medical expenses 

attributable to a physical injury resulting from a compensable crime, including 

expenses for mental health counseling and care; (2) loss of wages and support 

attributable to a physical injury resulting from a compensable crime; and 

(3) funeral expenses attributable to a death resulting from a compensable crime.2 

1 The VOCA victim compensation formula program is funded under 34 U.S.C. § 20102. 

2 This program defines criminal violence to include drunk driving and domestic violence. 

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The Grantee 

As the Vermont state administering agency, the Vermont Center for Crime 

Victim Services (VCCVS) was responsible for administering the VOCA victim 

compensation program grants.3 According to its website, VCCVS’s mission is to 

provide leadership to the state to ensure that justice is delivered to all victims and 

survivors of crime through recognition of harm done and advocacy for their rights 

and needs. Although VCCVS is a state-related agency funded primarily from state 

appropriations and grants, it is staffed by non-state employees. 

OIG Audit Approach 

The objective of the audit was to evaluate how VCCVS designed and 

implemented its crime victim compensation program. To accomplish this objective, 

we assessed performance in the following areas of grant management: (1) grant 

program planning and execution, (2) program requirements and performance 

reporting, and (3) grant financial management. 

We tested compliance with what we consider the most important conditions 

of the grants. Unless otherwise stated in our report, we applied the authorizing 

VOCA legislation, the VOCA compensation program guidelines (VOCA Guidelines), 

and the DOJ Grants Financial Guide as our primary criteria. We also reviewed 

relevant Vermont statutes; VCCVS policies, procedures, and guidelines; and 

interviewed VCCVS personnel to determine how they administered the VOCA funds. 

We further obtained and reviewed VCCVS records reflecting grant activity.4 

Additionally, we assessed VCCVS’s internal controls, implemented at the time of our 

audit, specific to the design, implementation, and operating effectiveness for those 

internal controls we deemed significant within the context of our audit objective. 

3 According to the Vermont Crime Victims statutes (13 V.S.A. 5361(b)), VCCVS is governed 

by and attached to the Victims Compensation Board for administrative support. 

4 Appendix 1 contains additional information on the audit’s objective, scope, and 

methodology, as well as further detail on the criteria we applied for our audit. 

2 
 

AUDIT RESULTS 

Grant Program Planning and Execution 

The main purpose of the VOCA victim compensation grants is to enhance 

state victim compensation payments to eligible crime victims. As part of our audit, 

we assessed VCCVS’s overall process for making victim compensation payments. 

We assessed VCCVS’s policies and procedures for providing compensation 

payments to victims, as well as the accuracy of the state certification form. 

Overall, we determined that VCCVS’s implementation of its victim 

compensation program was appropriate and in compliance with the VOCA 

Guidelines. We found VCCVS generally complied with federal grant requirements, 

and we did not identify any significant issues with its efforts to bring awareness to 

the program. Although we found that VCCVS established an adequate program 

with appropriate controls to compensate victims and survivors of criminal violence, 

we determined it should revise its policy and procedures for calculating lost wages 

and loss of support, as discussed later in this report. 

Program Implementation 

State administering agencies receive VOCA victim compensation grants to 

compensate victims for expenses incurred from criminal victimization. As the state 

administering agency for Vermont, VCCVS was responsible for the victim 

compensation program, including meeting all financial and programmatic 

requirements. In assessing VCCVS’s implementation of its victim compensation 

program, we analyzed policies and procedures governing the decision-making 

process for individual compensation claims. When paying claims for victims, VCCVS 

operated under its Victim Compensation Policy Documents, which conveyed the 

state-specific policies for awarding victim compensation. It also operated under its 

own internal policies, procedures, and guidelines specific to program administration. 

Based on our review, we found that VCCVS had an established application 

process for the intake, review, and payment or denial of individual compensation 

claims, and had adequate separation of duties between the employees who 

reviewed the claims and those with the authority to authorize payment. Also, we 

found that VCCVS’s program was generally consistent with the VOCA Guidelines. 

To enhance its state program and increase public awareness of available 

victim compensation benefits, VCCVS informed us that it provided victim 

compensation training to victim advocates statewide and service providers that 

received VOCA Victim Assistance grant funding. VCCVS’s website includes the 

victim compensation application, eligibility requirements, frequently asked 

questions, and video instructions for filling out an application that include an 

American Sign Language interpretation. We also found that VCCVS created victim 

notification slips for law enforcement personnel to distribute to victims and used 

social media to communicate program resources and events. 

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Inadequate Lost Wages and Loss of Support Policies and Procedures 

According to the VOCA Guidelines, states are mandated to award victim 

compensation for medical expenses, mental health counseling, lost wages, and 

funeral expenses. States may also offer compensation for other types of expenses 

authorized by state statute, rule, or other established policy. VCCVS administers 

the victim compensation program using its Victim Compensation Policy Documents, 

procedures, and guidelines. Based on our review, we determined VCCVS’s policies 

and procedures implemented at the time of our audit did not include adequate 

parameters for calculating compensation of lost wages and loss of support. 

Lost Wages 

VCCVS Victim Compensation Policy Documents specify that lost wages are 

calculated at 85 percent of a victim’s gross wages at the time of the loss and are 

limited to a maximum of $500 per week for 12 weeks.5 However, VCCVS may deny 

an award for lost wages when it is determined a claimant failed to report wages to 

state and federal taxing authorities, as required by law. 

During our claim file review, we determined VCCVS compensated one victim 

based on 19 weeks of employer pay stubs. Although the basis for the award was 

supported, we found that VCCVS’s policies and procedures did not define a period 

of time prior to the date of the crime for calculating gross wages or include details 

as to how VCCVS would calculate lost wages depending upon the claimant’s type of 

employment or available records. 

We discussed this issue with officials, and VCCVS provided revised policies 

and procedures for lost wages during our audit. Based on our review of the new 

guidance, we determined VCCVS strengthened their procedures; however, we 

determined the procedures did not define a period of time prior to the date of the 

crime for calculating gross wages and lacked details as to how lost wages will be 

calculated for different types of employment (e.g., seasonal, intermittent, or 

production-based pay employment). 

Loss of Support 

In Vermont, loss of support is paid to individuals victimized by a suspect for 

which they were dependent upon to maintain household expenses.6 VCCVS Victim 

Compensation Policy Documents specify that loss of support is paid to the suspect’s 

dependent based upon a suspect’s earnings, is calculated at 66.6 percent of the 

suspect’s gross monthly wages, and is limited to a maximum of $500 per week for 

12 weeks. VCCVS does not compensate victims based on unreported wages and 

5 Claimants are required to submit a physician’s report or a statement from a mental health 

provider in order to be eligible for reimbursement of more than 2 weeks. 

6 Loss of support is paid only to the dependents victimized by a suspect and does not 

compensate dependents of all criminal suspects or dependents of all victims. 

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may deny an award for lost wages when it is determined a claimant failed to report 

wages to state and federal taxing authorities. 

Based on our review, we determined VCCVS’s loss of support policy and 

procedures lacked guidance for the type of documentation it requires to 

substantiate a victim’s dependence on a suspect’s earnings to maintain household 

expenses. As an example, we found VCCVS compensated a claimant for loss of 

support at the maximum $6,000 allowable amount based on two weekly pay stubs. 

We determined the records VCCVS obtained adequately showed how VCCVS 

calculated the amount paid; however, the records provided were not adequate to 

demonstrate dependence on the suspect’s earnings to maintain household 

expenses. 

We discussed this claim with VCCVS officials and were told that the pay stubs 

were the only available records to support the claim. According to the Executive 

Director, it is sometimes difficult for claimants to obtain documentation for loss of 

support because claims are based on documentation provided by a suspect within a 

claim. As a result, it can be difficult or impossible to obtain documentation 

necessary to substantiate gross monthly wages. Additionally, officials informed us 

that VCCVS has decided not to require victims to provide bills and other receipts to 

demonstrate the level of support lost. 

During the audit, VCCVS provided its revised policy and procedures for 

compensating claimants for loss of support. We reviewed the policy and procedures 

and determined VCCVS added specific procedures for calculating gross monthly 

wages using tax returns and pay stubs. These revisions included procedures for 

prorating gross monthly wages when it obtains less than a month of pay stubs. 

However, the revisions did not address how VCCVS substantiates that claimants 

were dependent on a suspect’s earnings to maintained household expenses. 

We understand that it may be difficult for VCCVS to obtain documentation to 

substantiate loss of support for those claimants who are dependent on a suspect’s 

earnings and financial resources. However, this should not prevent VCCVS from 

designing and implementing policies and procedures that promote reasonable 

efforts to identify and obtain adequate documentation. This would help to ensure 

loss of support is paid in accordance with its policy. 

As a result, we recommend that OJP work with VCCVS to strengthen its 

policies and procedures for awarding lost wages and loss of support. 

Annual State Certification 

State administering agencies must submit an annual Crime Victim 

Compensation State Certification Form, which provides OVC the necessary 

information to accurately determine annual grant award amounts. The certification 

form must include all sources of funding available to the crime victim compensation 

program during the federal fiscal year, as well as the total of all compensation 

claims paid out to, or on behalf of, victims from all funding sources. The OVC 

allocates VOCA victim compensation formula grant funds to each state by 

5 
calculating 60 percent of the eligible compensation claims paid out to victims during 

the fiscal year 2 years prior.7 The accuracy of the information provided in the 

certification form is critical to OJP’s correct calculation of the victim compensation 

award amounts granted to each state. 

We attempted to assess VCCVS’s controls for preparing the annual 

certification forms submitted to the OVC for FYs 2014 through 2018, which is used 

to calculate the award amounts granted in FYs 2016 through 2020.8 Although 

VCCVS provided supporting documentation for its certifications, it was not possible 

to complete a reliable reconciliation of the certifications and accounting records 

because VCCVS did not have written policies and procedures for preparing its 

FY 2014-2017 certification forms and officials responsible for preparing the forms 

changed throughout this period. Based on the reconciliation we performed using 

available documentation, we determined the forms were not completed accurately. 

We attributed the discrepancies to unsupported payments in 2014 and 2015 

and inadequate procedures for certifying refunds, payment corrections, and funds 

transferred between accounts used for state and federal expenditures. However, 

the errors resulted in VCCVS receiving less funding in all years except FY 2016 and 

2017, when it received approximately $1,000 more than it should have received. 

We discussed these discrepancies with VCCVS officials who agreed the forms were 

not prepared accurately and that procedures were not adequate to ensure the 

forms were submitted accurately. During the audit, VCCVS identified and corrected 

minor errors to its FY 2018 certification. 

VCCVS provided us with its written instructions for preparing the 

certifications, which were documented in June 2019 and revised during the audit to 

include changes made as a result of our analysis. VCCVS also provided new 

expenditure coding policies and procedures that it plans to implement on 

July 1, 2020. Based on our review, we determined these two documents, when 

fully implemented, should improve VCCVS’s certification process. 

Sexual Assault Examination Costs 

According to the VOCA Guidelines, one of the primary purposes of the OVC 

Victim Compensation Grants is to encourage victim cooperation and participation in 

the criminal justice system and the reasonable requests of law enforcement. To 

achieve this, the Guidelines state that crime victim compensation programs must 

promote victim cooperation with the reasonable requests of law enforcement 

authorities and requires states to establish acceptable criteria to encourage and 

document cooperation. 

7 The eligible payout amount for award consideration is determined after deducting payments 

made with VOCA funds, subrogation and restitution recoveries, refunds, amounts awarded for 

property loss, and other reimbursements. 

8 The OJP’s Office of the Chief Financial Officer, Budget Execution Division calculates the 

allocations for VOCA eligible crime victim compensation programs, and OVC makes the grant awards. 

6 
 

The state of Vermont established compensation programs for victims of crime 

and victims of sexual assault under separate statutes.9 One statute authorizes 

payments to victims of crime only if a law enforcement officer has filed a report 

concluding that a crime was committed that resulted in the injury (physical or 

emotional) or death of the victim. We determined a separate set of statutes 

authorizes the state to pay the costs for sexual assault examinations (SAE) on 

behalf of victims of sexual assault that have not yet reported their crimes to law 

enforcement and provide victims with the right to decline to have a forensic medical 

exam completed.10 

Based on our review and discussions with officials, VCCVS charged to its 

federal victim compensation grants and included on its state certification forms all 

sexual assault examination costs regardless of a victim’s cooperation with law 

enforcement. Although VCCVS officials explained to us that it considers cooperation 

with the reasonable requests of law enforcement to include victims of sexual 

assault that have a forensic medical exam completed, we determined that VCCVS 

had not documented its standard of cooperation. At the time of our audit, VCCVS 

had not implemented a process to obtain and track data necessary to determine 

whether a victim had cooperated with law enforcement. 

Therefore, we recommend OJP ensure VCCVS establish appropriate criteria to 

encourage and document cooperation with law enforcement for victims of sexual 

assault. We also recommend OJP ensure VCCVS design and implement policies and 

procedures to obtain and track data necessary to ensure that only costs paid on 

behalf of victims of sexual assault that align with Vermont’s established criteria for 

cooperation with law enforcement are charged to its federal victim compensation 

grants and included on its state certification forms. 

Program Requirements and Performance Reporting 

To determine whether VCCVS distributed VOCA victim compensation program 

funds to compensate victims of crime, we reviewed VCCVS performance measures 

and performance documents that VCCVS used to track goals and objectives. We 

further examined OVC solicitations and award documents and verified VCCVS 

compliance with special conditions governing recipient award activity. 

Based on our overall assessment in the areas of program requirements and 

performance reporting, we believe that VCCVS: (1) implemented adequate 

procedures to compile annual performance reports, and (2) complied with the 

special conditions we tested. 

9 The referenced Vermont statues for sexual assault include 3 V.S.A. § 21, 32 V.S.A. § 1407, 

8 V.S.A. § 4089, and 13 V.S.A. § 3251-3281. 

10 According to Vermont statute (8 V.S.A. § 4089), ‘sexual assault examination’ means “either 

or both of the following: (A) a physical examination of the patient, documentation of biological and 

physical findings, and collection of evidence; and (B) treatment of the patient’s injuries; providing care 

for sexually transmitted infections; assessing pregnancy risk; discussion of treatment options, 

including reproductive health services, screening for human immunodeficiency virus, and prophylactic 

treatment, when appropriate; and providing instructions and referrals for follow-up care.” 

7 
 

 

Annual Performance Reports 

Each state administering agency must annually report to the OVC on activity 

funded by any VOCA awards active during the federal fiscal year. The reports are 

submitted through OJP’s Grants Management System (GMS). The OVC also 

requires states to submit quarterly performance data through the web-based 

Performance Measurement Tool (PMT). After the end of the fiscal year, State 

Administering Agencies are required to produce the Annual State Performance 

Report and upload it on GMS. 

For the victim compensation grants, states must report the number of 

victims for whom an application was made; the number of victims whose 

victimization is the basis for the application; victim demographics; the number of 

applications that were received, approved, denied, and closed; and total 

compensation paid by service type. 

VCCVS used its electronic case management system to prepare its quarterly 

and annual performance reports. To assess VCCVS’s performance, we tested a 

sample of metrics from VCCVS’s federal FY 2018 quarterly performance reports by 

comparing system reports VCCVS generated during the audit to its FY 2018 

quarterly performance reports submitted to OVC. 

Based on our review, the performance data did not match precisely, with 

some metrics being underreported and others over-reported. However, VCCVS was 

able to provide contemporaneous evidence to support these discrepancies. As a 

result, we determined VCCVS’s performance reports were adequately supported. 

Compliance with Special Conditions 

The special conditions of a federal grant award establish specific 

requirements for grant recipients. In its grant application documents, VCCVS 

certified it would comply with these special conditions. We reviewed the special 

conditions for each of the VOCA victim compensation program grants and identified 

special conditions that we deemed significant to grant performance that are not 

otherwise addressed in another section of this report. We judgmentally selected 

the following three special conditions to review in greater detail: 

1. Ensure that at least one key grantee official attends the annual VOCA 

National Training Conference. 

2. Both the Point of Contact and all Financial Points of Contact for this 

award must have successfully completed the OJP Financial 

Management and Grant Administration Training. 

3. Collect information regarding race, sex, and age of recipients of 

compensation benefits, where such information is voluntarily furnished. 

We found that VCCVS complied with the special conditions we tested. 

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Grant Financial Management 

Award recipients must establish an adequate accounting system and 

maintain financial records that accurately account for awarded funds. To assess the 

adequacy of VCCVS’s financial management of the VOCA victim compensation 

grants, we reviewed the process VCCVS used to administer these funds by 

examining expenditures charged to the grants, subsequent drawdown requests for 

funding reimbursement, and resulting financial reports. To further evaluate 

VCCVS’s financial management of the VOCA victim compensation grants, we 

reviewed the Single Audit Report for FY 2018 but did not identify any significant 

deficiencies or material weaknesses specifically related to VCCVS. We also 

interviewed VCCVS personnel who were responsible for financial aspects of the 

grants, reviewed VCCVS written policies and procedures, inspected award 

documents, and reviewed financial records. 

As discussed below, in our overall assessment of grant financial 

management, we determined that VCCVS implemented adequate controls over its 

victim compensation program. However, we found that VCCVS did not implement 

accounting procedures that complied with the grant award requirements, and 

VCCVS could not support its quarterly Federal Financial Reports (FFR). 

Grant Expenditures 

State administering agency VOCA compensation expenses fall into two 

overarching categories: (1) compensation claim payments – which constitute the 

vast majority of total expenses, and (2) administrative expenses – which are 

allowed to total up to 5 percent of each award. To determine whether costs 

charged to the awards were allowable, supported, and properly allocated in 

compliance with award requirements, we tested a sample of transactions from each 

of these categories by reviewing accounting records and verifying support for select 

transactions. 

Victim Compensation Claim Expenditures 

Victims of crime in the state of Vermont submit claims for reimbursement of 

expenses incurred as a result of victimization, such as medical and funeral costs, 

lost wages, loss of support, and other expenses authorized by VCCVS as eligible 

expenses. VCCVS staff adjudicate these claims for eligibility and make payments 

from the VOCA victim compensation grants and state funding. 

To evaluate VCCVS’s financial controls over VOCA victim compensation grant 

expenditures, we reviewed victim compensation claims to determine whether the 

payments were accurate, allowable, timely, and in accordance with the VOCA 

Guidelines and Vermont victim compensation policies, guidelines, and procedures. 

We judgmentally selected a sample of 49 payments, totaling $44,940 paid to 

20 individual claimants. The transactions we reviewed included costs in the 

following categories: lost wages, loss of support, mental health, travel, relocation, 

childcare, and crime-scene cleanup. 

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Based on our testing, we determined that most expenditures were allowable, 

supported by adequate documentation, and approved in accordance with VCCVS 

policies, procedures, and guidelines. As discussed earlier in this report in the Grant 

Program Planning and Execution section, we determined VCCVS’s lost wage and 

loss of support policies and procedures did not provide specific parameters for 

calculating compensation. Despite this shortcoming in VCCVS’s policies and 

procedures, we determined the lost wages and loss of support we tested complied 

with VCCVS’s guidelines in place at the time of the audit. 

Administrative Expenditures 

State administering agencies may retain up to 5 percent of each grant to pay 

for administering its crime victim compensation program. However, such costs 

must derive from efforts to improve program effectiveness and service to crime 

victims, including claims processing, staff development and training, and public 

outreach. For VCCVS’s compensation grant program, we tested compliance with 

the 5 percent limit on the administrative category of expenditures, as shown in 

Table 2. 

Table 2 

Administrative Expenditures as of September 2019 

Award Number Total Award 

State 

Administrative 

Expenditures 

Administrative 

Percentage 

2016-VC-GX-0045 $274,000 $13,700 5% 

2017-VC-GX-0044 $119,000 $3,566 3% 

Source: OIG Analysis of VCCVS Records 

We found that VCCVS complied with the 5 percent administrative allowance. 

Of the total administrative expenditures associated with the 2016 and 2017 awards, 

VCCVS charged $10,953 in travel expenditures. We tested a sample of $4,227 in 

travel expenditures, representing more than 24 percent of total administrative 

costs, and determined these expenditures were generally allowable and supported. 

Grant Accounting 

According to the DOJ Grants Financial Guide, there is no financial 

requirement to identify the source of individual payments to crime victims as either 

federal or state dollars, nor is there any requirement that restitution recoveries or 

other refunds be tracked to federal or state dollars paid out to victims. However, 

the state agency administering funds under this program must have an adequate 

accounting system to separately track receipts and expenditures, and to support 

financial reporting that is accurate, current, complete, and compliant with all 

financial reporting requirements of the award. Although VCCVS tracked federal and 

state expenditures separately in its accounting system, we determined VCCVS did 

not establish a unique account number or project code that would allow for 

separate accounting and tracking of each DOJ grant. 

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VCCVS had to use a supplemental spreadsheet to track the total amount of 

expenditures allocated to each of its grants before preparing FFRs and calculating 

drawdown requests. Although VCCVS tracked expenditure total amounts allocated 

to each of its awards, the accounting system and spreadsheets did not identify a 

specific set of expenditures allocable to each grant award number. As a result, we 

determined VCCVS’s accounting procedures failed to segregate expenditures by 

recording grant funded payments in the same account without the ability to 

delineate by specific grant. 

We discussed the accounting procedures with VCCVS official responsible for 

fiscal administration and were told that the accounting procedures were based on 

legacy procedures. During the audit, VCCVS provided the OIG with revised 

accounting policies and procedures it plans to implement on July 1, 2020. Based on 

our review, we determined the revised policies and procedures, when fully 

implemented, should address the segregation of victim compensation expenditures. 

We recommend OJP ensure VCCVS implement its revised accounting policies 

and procedures to ensure expenditures are tracked separately by grant award 

number. 

CBD Oil 

VCCVS requested guidance from OVC on the allowability of the costs 

associated with medical marijuana and CBD oil, which are not allowed to be funded 

by federal grants. OVC confirmed to VCCVS that medical marijuana, including CBD 

oil, cannot be charged to federal grants and should be excluded from consideration 

from victim compensation payments included in the Victim Compensation Program 

formula used to determine a state’s award total. Based on our review of its 

certifications, we determined VCCCVS charged $71.24 to its FY 2016 grant. We did 

not question these costs because the amount was considered immaterial. 

Additionally, during the audit, VCCVS revised its accounting procedures to ensure 

these costs are not charged to its federal grants in the future. 

Financial Reporting 

According to the DOJ Grants Financial Guide, recipients shall report the 

actual expenditures and unliquidated obligations incurred during the reporting 

period on each financial report as well as cumulative expenditures. To determine 

whether VCCVS submitted accurate FFRs, we compared the reports to VCCVS’s 

accounting records for each grant. 

We determined that quarterly expenditures for the reports reviewed were 

less than VCCVS’s accounting system and supplemental records; however, VCCVS 

did not maintain supporting documentation. Based on the fact that the FFRs were 

less than actual expenditures, we determined the errors were potentially caused by 

expenditures transferred to the grant account after the FFRs were submitted. 

Although the amounts were immaterial, we found that VCCVS continuously updated 

its tracking spreadsheets to adjust total expenditures charged to the grant account. 

As a result, we determined VCCVS should have revised its FFRs. 

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After completing our analysis, VCCVS submitted its written FFR and 

drawdown procedures, which it added to its Financial Policies and Procedures 

Manual in February 2020. We reviewed these procedures and determined they 

were designed for grants that have subrecipients, include instructions that may 

cause FFRs to be prepared incorrectly, and did not include procedures to ensure 

FFRs are revised when previously reported expenditures are adjusted. 

Therefore, we recommend OJP ensure VCCVS revise its Financial Policies and 

Procedures Manual to ensure FFRs are accurate and supported by accounting 

system records. 

Drawdowns 

Award recipients are to request funds based upon immediate disbursement 

or reimbursement needs, and grantees should time drawdown requests to ensure 

that the federal cash on hand is the minimum needed for disbursements or 

reimbursements made immediately or within 10 days. VOCA victim compensation 

grant funds are available for the fiscal year of the award plus 3 additional fiscal 

years. To assess whether VCCVS managed grant receipts in accordance with these 

federal requirements, we compared the total amount reimbursed to the total 

expenditures in VCCVS’s accounting system and accompanying financial records. 

For the VOCA victim compensation awards, VCCVS requested drawdowns on 

a reimbursement basis. Table 3 shows the total amount drawn down for each grant 

as of February 2020. 

Table 3 

Amount Drawn Down for Each Grant as of February 2020 

Award Number Award Period 

End Date Total Award Amount 

Drawn Down 

Amount 

Remaining 

2016-VC-GX-0045 9/30/2019 $274,000 $274,000 $0 

2017-VC-GX-0044 9/30/2020 119,000 118,416 584 

Total: $393,000 $392,416 $584 

Source: OJP Records 

During this audit, we did not identify deficiencies related to the recipient’s 

process for developing drawdown requests. Further, VCCVS provided us with 

adequate supporting documentation for the drawdowns we tested. We also 

determined that VCCVS complied with the minimum cash on hand requirement. 

12 
 

CONCLUSION AND RECOMMENDATIONS 

We found VCCVS generally used its grant funds to compensate crime victims 

according to the terms and conditions of the awards. We did not take issue with 

VCCVS’s use of administrative funding or drawdown requests. However, we 

identified several opportunities where VCCVS could improve its programmatic and 

fiscal policies. We provide five recommendations to OJP to address these 

deficiencies. 

We recommend that OJP: 

1. Ensure VCCVS establish appropriate criteria to encourage and document 

cooperation with law enforcement for victims of sexual assault. 

2. Ensure VCCVS design and implement policies and procedures to obtain and 

track data necessary to ensure that only costs paid on behalf of victims of 

sexual assault that align with Vermont’s established criteria for cooperation 

with law enforcement are charged to its federal victim compensation grants 

and included on its state certification forms. 

3. Work with VCCVS to strengthen its policies and procedures for awarding lost 

wages and loss of support. 

4. Ensure VCCVS implement its revised accounting policies and procedures to 

ensure expenditures are tracked separately by grant award number. 

5. Ensure VCCVS revise its Financial Policies and Procedures Manual to ensure 

FFRs are accurate and supported by accounting system records. 

13 
 

 

 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

The objective of the audit was to evaluate how VCCVS designed and 

implemented its crime victim compensation program. To accomplish this objective, 

we assessed performance in the following areas of grant management: (1) grant 

program planning and execution, (2) program requirements and performance 

reporting, and (3) grant financial management. 

Scope and Methodology 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objective. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objective. 

This was an audit of Victims of Crime Act (VOCA) victim compensation 

formula grants 2016-VC-GX-0045 and 2017-VC-GX-0044 from the Crime Victims 

Fund (CVF) awarded to VCCVS. The Office of Justice Programs (OJP), Office for 

Victims of Crime (OVC) awarded these grants, totaling $393,000, to VCCVS, which 

serves as the state administering agency. Our audit concentrated on, but was not 

limited to, the period of October 1, 2015, the project start date for VOCA 

compensation grant number 2016-VC-GX-0045, through April 2020. As of 

February 2020, VCCVS had drawn down a total of $392,416 from the two audited 

grants. 

To accomplish our objective, we tested compliance with what we consider to 

be the most important conditions of VCCVS’s activities related to the audited 

grants, which included conducting interviews with VCCVS financial staff, examined 

policies and procedures, and reviewed grant documentation and financial records. 

We performed sample-based audit testing for grant expenditures, progress reports, 

and grant award special conditions. In this effort, we employed a judgmental 

sampling design to obtain broad exposure to numerous facets of the grants 

reviewed. This non-statistical sample design did not allow projection of the test 

results to the universe from which the samples were selected. The authorizing 

VOCA legislation, the VOCA compensation program guidelines, the DOJ Grants 

Financial Guide, state compensation criteria, and the award documents contain the 

primary criteria we applied during the audit. 

During our audit, we obtained information from OJP’s Grants Management 

System as well as VCCVS accounting system specific to the management of DOJ 

funds during the audit period. We did not test the reliability of those systems as a 

whole; therefore, any findings identified involving information from those systems 

was verified with documents from other sources. 

14 
Internal Controls 

In this audit, we performed testing of internal controls significant within the 

context of our audit objectives. We did not evaluate the internal controls of VCCVS 

to provide assurance on its internal control structure as a whole. VCCVS 

management is responsible for the establishment and maintenance of internal 

controls in accordance with 2 C.F.R. § 200. Because we do not express an opinion 

on VCCVS’s internal control structure as a whole, we offer this statement solely for 

the information and use of VCCVS and OJP.11 

In planning and performing our audit, we identified the following internal 

control components and underlying internal control principles as significant to the 

audit objective: 

Internal Control Components & Principles Significant to the Audit Objectives 

Control Activity Principles 

Management should design control activities to achieve objectives and respond to risks. 

Management should design the entity’s information system and related control activities to 

achieve objectives and respond to risks. 

Management should implement control activities through policies. 

Information & Communication Principles 

Management should use quality information to achieve the entity’s objectives. 

We assessed the design, implementation, and operating effectiveness of 

internal controls significant to the audit objective and performance areas we tested. 

We identified deficiencies that we believe could affect VCCVS’s ability to effectively 

and efficiently operate, to correctly state financial and performance information, 

and to ensure compliance with laws and regulations. The internal control 

deficiencies we found are discussed in the Audit Results section of this report. 

However, because our assessment was limited to aspects of internal control 

components and principles significant to the objective of this audit, it may not have 

disclosed all internal control deficiencies that may have existed at the time of this 

audit. 

11 This restriction is not intended to limit the distribution of this report, which is a matter of 

public record. 

15 
APPENDIX 2 

VERMONT CENTER FOR CRIME VICTIM SERVICES RESPONSE TO 

THE DRAFT AUDIT REPORT12 

~ .VERMONT 

Center for Crime Victim Services [phone] 802-241-1250 

58 South Main Street, Suite 1 [phone] 800-7 50-1213 

Waterbury, Vf 05676-1599 [fax] 802-241-1253 (Victims Compensation only) 

www.ccvs.vermont.gov [fax] 802-241-43 3 7 (General fax ) 

Thomas Puerzer 

Office of Justice Programs 

Office of Audit, Assessment, and Management 

810 Seventh Street, NW 

Washington, D.C. 20531 

June 30, 2020 

Dear Mr. Puerzer: 

There are five recommendations and VCCVS is addressing each recommendation and 

including additional documentation to show the changes that has made. 

Recommendation 1 

Ensure VCCVS establish appropriate criteria to encourage and document cooperation 

with law enforcement for victims of sexual assault. 

Initial Response: 

VCCVS concurs with this recommendation. The sexual assault billing form/instructions will 

now include SANE acknowledgement that victim of sexual assault was provided with 

information about and the option of forensic evidence collection, the victim was provided 

with the information regarding reporting the crime to law enforcement, the forensic kit 

number if a forensic kit was completed, and if the victim declined the forensic kit. 

ATTACHMENTS 

1. Sexual Assault Billing Form 

2. Criteria Cooperation with Law Enforcement 

Responsible Party: 

• Carol Morgan, Compensation Manager 

• 802-241-1250 

Recommendation 2 

Ensure VCCVS design and implement policies and procedures to obtain and track 

data necessary to ensure that only costs paid on behalf of victims of sexual assault 

that align with Vermont's established criteria for cooperation with law 

enforcement are charged to its federal victim compensation grants and included on 

its state certification forms. 

Response: 

VCCVS concurs with this recommendation. VCCVS in process of implementing systems that 

will: Tracking data in CCVS database to ensure that the costs paid by the SAE Program 

1 

12 Attachments referenced in this response were not included in the final report. 

16 
~ .VERMONT 

Center for Crime Victim Services [phone] 802-241-1250 

58 South Maiu Street, Suite 1 [phone] 800-750-1213 

Waterbury, vr 05676-1599 [fa.,] 802-241-1253 (Victims Compeusatiou ouly) 

www .ccvs.vermont.gov [fax] 802-241-4337 (General fax) 

align with the criteria for cooperation with law enforcement as well as meet statutory 

requirements for payment of eligible medical/forensic expenses by the SAE Program. 

ATTACHMENTS 

3. Criteria Cooperation with Law Enforcement 

4. Sexual Assault Billing Form 

Responsible Party: 

• Carol Morga n, Compensation Manager 

• 802-241-1250 

Recommendation 3 

Work with VCCVS to strengthen its policies and procedures for awarding lost wages 

and loss of support. 

Response: 

VCCVS concurs with this recommendation. VCCVS Compensation Program has revised the 

Lost Wage Policy Procedures along with strengthening the eligibility, calculation of lost 

wages and description of employment. 

VCCVS has also updated the Loss of Support Verification Form and updated the Loss of 

Support Procedures. 

ATTACHMENTS 

5. Lost Wage Policy a nd Procedures 

6. Loss of Support Verification Form 

7. Loss of Support Procedures 

Responsible Party: 

• Carol Morgan, Compensation Ma nager 

• 802-241-1250 

Recommendation 4 

Ensure VCCVS implement its revised accounting policies and procedures to ensure 

expenditures are tracked separately by grant award number. 

Response: 

VCCVS concurs with this recommendation. VCCVS has added la nguage to the policy to note 

the duty of the Finance Director in assigning the grant award number to each invoice a nd 

having that entered into the spreadsheet and system. 

2 

17 
~ .VERMONT 

Center for Crime Victim Services [ph one] 802-241-1250 

58 South Main Street, Suite 1 [phone] 800-750-1213 

Waterbury, vr 05676-1599 [fox] 802-241-1253 {Victims Compensation only) 

www.ccvs.vermont.gov [fax] 802-241-4337 (General fax) 

ATTACHMENTS 

8. How to Process Compensation Claims within the VISION system and VCCVC 

pages 6-25 

Responsible Party: 

• Carol Brochu, Finance Manager 

• 802-241-1250 

Recommendation 5 

Ensure VCCVS revise its Financial Policies and Procedures Manual to ensure 

FF Rs are accurate and supported by accounting system records. 

Response: 

VCCVS concurs with this recommendation. VCCVS has developed and implemented new 

written FFR policies and procedures. VCCVS is now using updated VCCVS Grants & Finance 

Workflow & Procedures as reference for submitting FFR. 

ATTACHMENTS 

9. How to Process Compensation Claims within the VISION system and VCCVC page 

35 

Responsible Party: 

• Carol Brochu, Finance Manager 

• 802-241-1250 

Again. thank you for the opportunity to respond to the recommendations. 

Chris Fenno 

Executive Director 

802-241-1250 x 106 

3 

18 
APPENDIX 3 

OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE DRAFT 

AUDIT REPORT 

U.S. Department of Justice 

Office of Justice Programs 

Office of Audit, Assessment, and Management 

Washington, D. C. 20531 

July 9, 2020 

MEMORANDUM TO: Thomas 0. Puerzer 

Regional Audit Manager 

Philadelphia Regional Audit Office 

Office of the Inspector General 

FROM: Ralph E. Ma~i_? ,1_ L , 

Director ~t,, ~ 

SUBJECT: Response to the Draft Audit Report, Audit of the Office of Justice 

Programs, Victim Compensation Grants Awarded to the Vermont 

Center for Crime Victim Services, Waterbu,y, Vermont 

This memorandum is in reference to your correspondence, dated June 10, 2020, transmitting the 

above-referenced draft audit report for the Vermont Center for Crime Victim Services (VCCVS). 

We consider the subject report resolved and request written acceptance of this action from your 

office. 

The draft rep01t contains five recommendations and no questioned costs. The following is the 

Office of Justice Programs' (OJP) analysis of the draft audit report recommendations. For ease 

of review, the recommendations are restated in bold and are followed by our response. 

1. We recommend that OJP ensure VCCVS establish appropriate criteria to 

encourage and document cooperation with law enforcement for victims of sexual 

assault 

OJP agrees with this recommendation. With its response to the draft audit report, 

VCCVS provided a copy of its Sexual Assault Billing Form and Criteria to Encourage 

and Document Cooperation with Law Enforcement. VCCVS stated that it is in the 

process of implementing a tracking system to determine whether a forensic kit was 

completed or declined by the victim, in order to ensure that the costs paid by the Sexual 

Assault Program align with the established criteria, as well as meet statutory 

requirements for payment of eligible medical/forensic expenses by the Sexual Assault 

Program. These procedures appear adequate to address this recommendation; however 

the process must be finalized. Accordingly, we will coordinate with VCCVS to obtain a 

copy of the approved and finalized policies and procedures, once the tracking system is 

completed. 

19 
2. We recommend that OJP ensure VCCVS design and implement policies and 

procedures to obtain and track data necessary to ensure that only costs paid on 

behalf of victims of sexual assault that align with Vermont's established ciiteria for 

cooperation with law enforcement are charged to its federal victim compensation 

grants and included on its state certification forms. 

OJP agrees with this recommendation. With its response to the draft audit report, 

VCCVS provided a copy of its Sexual Assault Billing Form and Criteria to Encourage 

and Document Cooperation with Law Enforcement. VCCVS stated that it is in the 

process of implementing a tracking system to determine whether a forensic kit was 

completed or declined by the victim, in order to ensure that the costs paid by the Sexual 

Assault Program align with the established criteria, as well as meet statutory 

requirements for payment of eligible medical/forensic expenses by the Sexual Assault 

Program. These procedures appear adequate to address this recommendation; however 

the process must be finalized. Accordingly, we will coordinate with VCCVS to obtain a 

copy of the approved and finalized policies and procedures, once the tracking system is 

completed. 

3. We recommend that OJP work with VCCVS to strengthen its policies and 

procedures for awarding lost wages and loss of suppo11. 

OJP agrees with this recommendation. With its response to the draft audit report, 

VCCVS provided a copy of Lost Wage Policy and Procedures, Loss of Support 

Verification Form, and Loss of Support Procedures, updated in June 2020. These 

policies appear adequate to address this recommendation; however, the forms and 

procedures provided were not signed and approved by a VCCVS authorizing official. 

Accordingly, we will coordinate with VCCVS to obtain a copy of the approved and 

finalized policies and procedures. 

4. We recommend that OJP ensure VCCVS implement its revised accounting policies 

and procedures to ensure expenditures are tracked separately by grant award 

nwnber. 

OJP agrees with this recommendation. With its response to the draft audit report, 

VCCVS provided a copy of How to Process Compensation Claims. VCCVS stated that 

the Finance Director will enter the Project Code in the State of Vermont VISION 

Financial System, as part of the year end procedures to separately track expenditures by 

grant award number. These procedures appear adequate to address this recommendation; 

however, the procedures provided were not signed and approved by a VCCVS 

authorizing official. Accordingly, we will coordinate with VCCVS to obtain a copy of 

the approved and finalized policies and procedures. 

2 

20 
5. We recommend that OJP ensure VCCVS revise its Financial Policies and 

Procedures Manual to ensure Federal Financial Reports (FFRs) are accurate and 

supported by accounting system records. 

OJP agrees with this recommendation. With its response to the draft audit report. 

VCCVS provided a copy of its FFR Policy and Procedures Manual. However. OJP does 

not believe that VCCVS has adequately addressed this recommendation, as the Manual 

does not specifically state that Federal Financial Reports will be completed using 

accounting system records; nor that the records will be maintained for auditing purposes. 

In addition, the Manual provided was not signed and approved by an authorizing VCCVS 

official. Accordingly, we will coordinate with VCCVS to obtain written policies and 

procedures, developed and implemented, to ensure that it completes its FFRs, based on 

grant-related expenditure data from its financial management system. 

We appreciate the opportunity to review and comment on the draft audit report. If you have any 

questions or require additional information, please contact Jeffery A. Haley, Deputy Director, 

Audit and Review Division, on (202) 616-2936. 

cc: Katharine T. Sullivan 

Principal Deputy Assistant Attorney General 

Maureen A. Henneberg 

Deputy Assistant Attorney General 

for Operations and Management 

LeToya A. Johnson 

Senior Advisor 

Office of the Assistant Attorney General 

Jeffery A. Haley 

Deputy Director, Audit and Review Division 

Office of Audit, Assessment, and Management 

Jessica E. Hart 

Director 

Office for Victims of Crime 

Bill Woolf 

Senior Advisor 

Office for Victims of Crime 

Katherine Darke-Schmitt 

Deputy Director 

Office for Victims of Crime 

3 

21 
cc: Kathrina S. Peterson 

Acting Deputy Director 

Office for Victims of Crime 

James Simonson 

Associate Director for Operations 

Office for Victims of Crime 

Ramesa Pitts 

Grants Management Specialist 

Office for Victims of Crime 

Charlotte Grzebien 

Deputy General Counsel 

Silas V. Darden 

Director 

Office of Communications 

Leigh A. Benda 

Chief Financial Officer 

Christal McNeil-Wright 

Associate Chief Financial Officer 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Joanne M. Suttington 

Associate Chief Financial Officer 

Finance, Accounting, and Analysis Division 

Office of the Chief Financial Officer 

AidaBrumme 

Manager, Evaluation and Oversight Branch 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Louise Duhamel 

Acting Assistant Director, Audit Liaison Group 

Internal Review and Evaluation Office 

Justice Management Division 

OJP Executive Secretariat 

Control Number IT20200611084105 

4 

22 
APPENDIX 4 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT 

The OIG provided a draft of this audit report to the Office of Justice Programs 

(OJP) and the Vermont Center for Crime Victim Services (VCCVS). VCCVS’s 

response is incorporated in Appendix 2, and OJP’s response is in Appendix 3 of this 

final report. VCCVC concurred with all our recommendations and provided revised 

policies and procedures demonstrating its design and implementation of corrective 

action prepared in response to the draft report. 

OJP agreed with our recommendations and discussed the actions it plans to 

complete to address our recommendations. As a result, the status of the audit 

report is resolved. The following provides the OIG analysis of the responses and a 

summary of the actions necessary to close the report. 

Recommendations for OJP: 

1. Ensure VCCVS establish appropriate criteria to encourage and 

document cooperation with law enforcement for victims of sexual 

assault. 

Resolved. OJP agreed with our recommendation. OJP said in its response 

that VCCVS is in the process of implementing a tracking system to determine 

whether a forensic kit was completed or declined by the victim to ensure that 

the costs paid by the Sexual Assault Program align with the established 

criteria, as well as meet statutory requirements for payment of eligible 

medical/forensic expenses by the Sexual Assault Program. OJP found that 

VCCVS’s procedures appear adequate to address the recommendation but 

noted that the process was not finalized. OJP stated it will coordinate with 

VCCVS to obtain a copy of the approved and finalized policies and procedures 

once the tracking system is completed. 

VCCVS concurred with this recommendation. As part of its response, VCCVS 

provided its Criteria to Encourage and Document Cooperation with Law 

Enforcement and revised Sexual Assault Billing Form for Crimes that Occur in 

Vermont. In addition to these documents, VCCVS also noted in its response 

to recommendation number 2, that it was in process of working with an 

outside vendor on implementing a tracking system to ensure eligible 

medical/forensic expenses are paid by the Sexual Assault Program. 

This recommendation can be closed when we receive documentation 

demonstrating VCCVS established appropriate criteria to encourage and 

document cooperation with law enforcement for victims of sexual assault. 

23 
2. Ensure VCCVS design and implement policies and procedures to 

obtain and track data necessary to ensure that only costs paid on 

behalf of victims of sexual assault that align with Vermont’s 

established criteria for cooperation with law enforcement are 

charged to its federal victim compensation grants and included on its 

state certification forms. 

Resolved. OJP agreed with our recommendation. OJP said in its response 

that VCCVS is in the process of implementing a tracking system to determine 

whether a forensic kit was completed or declined by the victim to ensure that 

the costs paid by the Sexual Assault Program align with the established 

criteria, as well as meet statutory requirements for payment of eligible 

medical/forensic expenses by the Sexual Assault Program. OJP found that 

VCCVS’s procedures appear adequate to address the recommendation but 

noted that the process was not finalized. OJP stated it will coordinate with 

VCCVS to obtain a copy of the approved and finalized policies and procedures 

once the tracking system is completed. 

VCCVS concurred with this recommendation. As part of its response, VCCVS 

provided its revised Sexual Assault Examination form that includes data 

collection fields that track whether a victim chose to have completed or 

declined a forensic examination. However, VCCVS also stated that it is 

currently working with its outside vendor to design and implement a tracking 

system necessary to document this data. 

This recommendation can be closed when we receive documentation 

demonstrating VCCVS designed and implemented policies and procedures to 

obtain and track data necessary to ensure that only costs paid on behalf of 

victims of sexual assault that align with Vermont’s established criteria for 

cooperation with law enforcement are charged to its federal victim 

compensation grants and included on its state certification forms. 

3. Work with VCCVS to strengthen its policies and procedures for 

awarding lost wages and loss of support. 

Resolved. OJP agreed with our recommendation. OJP said in its response 

that it reviewed the Lost Wage Policy and Procedures, Loss of Support 

Procedures, and Loss of Support Verification Form provided with VCCVS’s 

response and determined the policies appear adequate to address this 

recommendation; however, the forms and procedures provided were not 

signed and approved by a VCCVS authorizing official. OJP stated further that 

it would coordinate with VCCVS to obtain a copy of the approved and 

finalized policies and procedures. 

VCCVS concurred with this recommendation. We reviewed the revised 

policies and procedures provided by VCCVS and determined VCCVS added 

definitions for different types of wages and procedures for determining an 

employee’s rate of pay. For the revised Loss of Support Procedures and Loss 

of Support Verification Form, we determined the procedures were revised to 

24 
 

more clearly define some sources of financial support. We also found that 

the Loss of Support Verification Form requires victims or dependents to: 

(1) certify that they were living with the suspect and financially dependent on 

the suspect’s income to maintain household expenses, and (2) identify the 

period of time for which they are seeking loss of support. 

This recommendation can be closed when we receive documentation 

demonstrating OJP worked with VCCVS to strengthen its policies and 

procedures for awarding lost wages and loss of support, and that those 

policies and procedures have been implemented. 

4. Ensure VCCVS implement its revised accounting policies and 

procedures to ensure expenditures are tracked separately by grant 

award number. 

Resolved. OJP agreed with our recommendation. OJP said in its response 

that it reviewed the How to Process Compensation Claims document, 

provided with VCCVS’s response, and determined the procedures appear 

adequate; however, the document was not signed and approved by a VCCVS 

authorizing official. OJP stated further that it would coordinate with VCCVS 

to obtain a copy of the approved and finalized policies and procedures. 

VCCVS concurred with this recommendation and provided a copy of its 

accounting policies and procedures revised during the audit. 

This recommendation can be closed when we receive documentation 

demonstrating VCCVS revised its accounting policies and procedures have 

been signed by an authorizing official. 

5. Ensure VCCVS revise its Financial Policies and Procedures Manual to 

ensure Federal Financial Reports (FFR) are accurate and supported 

by accounting system records. 

Resolved. OJP agreed with our recommendation. OJP said in its response 

that it reviewed the FFR Policy and Procedures Manual and determined that it 

did not specifically state that FFRs will be completed using accounting system 

records or that the records will be maintained for audit purposes. OJP also 

commented that the Manual was not signed by an authorizing official. OJP 

further stated that it would coordinate with VCCVS to obtain a copy of the 

approved and finalized policies and procedures that ensure it completes its 

FFRs based on grant-related expenditure data extracted from its accounting 

system. 

VCCVS concurred with this recommendation and provided its revised FFR and 

drawdown policies and procedures for completing FFRs. We reviewed the 

document and determined that the manual requires FFRs to be prepared 

using Vermont’s accounting system data and were revised to include screen 

shots of the FFRs and the Grants Payment Request System (GPRS) to aid in 

completing FFRs and reimbursement requests. However, we determined the 

25 
FFR procedures were not revised to eliminate language limiting the policy to 

grants that involve subrecipients and did not include procedures for 

submitting revised reports. 

This recommendation can be closed when we receive documentation 

demonstrating VCCVS revised its Financial Policies and Procedures Manual to 

ensure FFRs are accurate and supported by accounting system records. 

26