Audit of Attorney General’s Consumer Assistance Program Finds Vermonters’ Complaints Generally Handled Promptly and Professionally, Procedures and Performance Reporting Can be Improved
Recommendations include updating complaint handling procedures and adopting a methodology to more accurately quantify savings achieved through CAP mediation
Vermont Business Magazine State Auditor Doug Hoffer released an audit today of how well the Attorney General’s Consumer Assistance Program (CAP) handles consumer complaints. The audit, the last in a series of four the Auditor’s Office has produced relating to how State government responds to Vermonters’ complaints, assessed the extent to which the CAP ensures consumer and business complaints are addressed in a timely manner. In addition, the audit evaluated whether the performance information reported by CAP is accurate and complete.
For several decades, Vermonters have been able to bring their consumer complaints to CAP, which is jointly operated by the Attorney General’s Office and the University of Vermont. While not a formal legal process, CAP mediation services are intended to help consumers and businesses by opening lines of communication to see if a complaint may be resolved.
In fiscal years 2023 and 2024, CAP attempted to mediate about 2,400 consumer complaints, including in the areas of home improvements, automotive and travel.
“The Attorney General’s CAP program is a great service to Vermonters,” said Auditor Hoffer. “Most people don’t have the time or the money to go to court when they feel like they’re getting shortchanged or ripped off, so a free mediation service is really useful. That said, it’s important that when Vermonters seek CAP’s help that they’re served effectively and efficiently.”
Highlights of the audit include:
- Consumers issues were fully or partially resolved in about half of the CAP mediation cases, resulting in financial or other tangible benefits.
- In a little more than two thirds of the complaints reviewed, CAP’s mediation process was completed within its 90-calendar day goal. However, in some cases CAP mediation process steps were delayed. For example, in about third of the 45 cases reviewed CAP did not initiate the mediation process for more than a business week after the complaints were received.
- In some cases CAP did not send follow-up letters to unresponsive businesses within its expected 10-day intervals, which may have delayed the completion of some cases. CAP lacks a tracking mechanism by which supervisors can see the complaint’s current mediation status to know whether expected mediation steps were performed and whether they were performed in a timely manner.
- Vermonters received meaningful financial recoveries and savings as a result of CAP mediation, though the amounts reported to the public were overstated. A review of 28 complaints for which CAP’s mediation process was completed in calendar years 2023 and 2024, including the ten highest recovery amounts from each of those years, found that for 12 of them (43 percent) CAP records were either insufficient to validate the accuracy of the resolution amounts or the documentation indicated that the recovery did not result or was unlikely to have resulted from the CAP mediation. For example, CAP recorded recoveries for complaints that it referred to other organizations and therefore were not the result of CAP mediations. In total, we found that CAP reported more than $800,000 in questionable recoveries in 2023 and 2024, caused at least in part by the lack of documented methodologies.
Hoffer added: “I want to commend the AG staff and UVM staff and students who help consumers and businesses find resolution to a wide variety of conflicts. The recommendations my team has made will make the CAP mediation process more consistent and effective, and will result in more accurate reporting on the program’s efforts to the public. I look forward monitoring their progress in the coming year.”
Appendix V — Comments from the Attorney General’s Office (Transcribed)
CHARITY R. CLARK
ATTORNEY GENERAL
STATE OF VERMONT
OFFICE OF THE ATTORNEY GENERAL
109 STATE STREET
MONTPELIER, VT 05609-1001
March 30, 2026
State Auditor Douglas Hoffer
State Auditor's Office
132 State Street
Montpelier VT 05633-5101
Dear Auditor Hoffer:
This letter serves as my Unit’s response to your report on the Vermont Consumer Assistance Program (CAP). I’m pleased that your office found that consumer complaints are generally addressed by CAP with significant benefits to Vermonters. Over the last three years we have implemented new procedures to improve efficiency and effectiveness of the program. I’m proud of this program and the progress we have made. We will always seek to learn and grow in order to enhance the services we provide to Vermonters. By way of example (and while not the subject of your review), enforcement actions related to CAP brought in $250,000 in payments benefiting taxpayers in the last year alone.
For over 40 years consecutive attorneys general have continued the service-learning program model between the Attorney General’s Office and the University of Vermont (UVM). CAP’s core services include not only the informal complaint mediation you mentioned in your report, but also outreach and education, referrals to the Attorney General’s consumer enforcement unit, legislative testimony and subject matter expertise, and job-training for students. Each semester, CAP trains approximately 10–15 undergraduate students who enroll in the CAP course to serve as CAP Advisers, building practical knowledge of Vermont’s consumer protection laws over the term. These students are trained to staff CAP’s hotline, facilitate mediations with businesses, and counsel Vermonters on how to recognize and respond to scams.
Through its work, CAP has assisted thousands of Vermonters and Vermont businesses in resolving disputes, navigating complex State processes, and responding to scams and fraud. All of this is achieved while also providing a foundation of professional skills for students who will soon begin careers in their chosen professions, including public service. It is also, of course, significantly less expensive to Vermont taxpayers than given that about a third of the cost of the program is paid for by UVM.
We appreciate the recommendations made in the report and will fully consider them alongside our existing training and procedures manuals. Thank you for your suggestions. In terms of reporting, we support a methodology that reflects the most accurate savings and recoveries reported to CAP by consumers and businesses. To the extent we may clarify or articulate that methodology in our Annual Report we will certainly do so if it is not already clear. To my knowledge, we are one of the only public-facing help agencies that provides a comprehensive Annual Report in hopes of providing the public greater transparency and insight into CAP’s work and results. We encourage the public to review our report for 2025 and reach out to my office with any questions.
Finally, I want to acknowledge the staff of the State Auditor’s Office (SAO) and CAP who worked together on the review of this essential program since it was initiated in April of 2025. This process was complicated by the inherent conflicts present when this audit began (and continued) while you had pending litigation against the Attorney General. Nonetheless, and as a courtesy, we cooperated fully for eleven months, and I am proud that the CAP team and the SAO staff were able to navigate this conflict successfully. Their dedication, hard work and professionalism is a credit to our offices. I know you are as proud of your staff as I am of our team at CAP.
Sincerely,
/s/ Christopher J. Curtis Assistant Attorney General. Director, Consumer Assistance Program Office of the Attorney General State of Vermont
The full audit can be found here.
4.8.2026. Office of the Vermont State Auditor, Montpelier auditor.vermont.gov
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