Corrective Action Plans

Finding 46428 (2022-002)

Significant Deficiency 2022

Baltimore Regional Housing Partnership, Inc.

MD

Reporting HUD Housing Programs Significant Deficiency

2022-002 Moving to Work Demonstration Program (HCVP Only) ? Federal Assistance Listing Number 14.881 Recommendation: The finding recommends BRHP perform their reporting to HUD on a weekly basis rather than on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement w...

2022-002 Moving to Work Demonstration Program (HCVP Only) ? Federal Assistance Listing Number 14.881 Recommendation: The finding recommends BRHP perform their reporting to HUD on a weekly basis rather than on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to the finding: At this time, all files selected for the audit have corresponding records successfully submitted to HUD through the PIC submission portal. BRHP will continue weekly PIC submissions and clearing of fatal errors and now have two staff trained on PIC submissions as a redundancy measure. It is not unusual for BRHP to process retroactive actions and at times, the effective date of the action can be for a date several weeks in the past. If PIC submissions are completed weekly rather than monthly, there will be more opportunities to upload the 50058 in accordance with the 60-day required period. BRHP explored the possibility of submitting a Moving To Work activity specifically to allow for PIC submissions of retroactive actions past the 60-day window, however, ultimately decided it was not an activity that would fall within the regulatory framework for the Moving To Work program. As a result, BRHP will limit retroactive actions to no more than 45-days prior to effective date, ensuring ample time for submission prior to the 60-day window lapsing. Names(s) of the contact person(s) responsible for correction action: FaShaunDa Walton, Housing Mobility Director Planned completion date for corrective action plan: August 31, 2023 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Adria Crutchfield at (667) 207-2140.

View Audit 41048

Finding 46426 (2022-003)

Significant Deficiency 2022

City of Cape Coral, Florida

FL

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-003 Community Development Block Grant ? Assistance Listing Number: 14.218 Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as requir...

FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2022-003 Community Development Block Grant ? Assistance Listing Number: 14.218 Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as required by grant agreements. We recommend the City develop an internal compliance checklist that includes required reports and due dates to be maintained for tracking and record keeping purposes to assist in monitoring compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: City could not log into the federal system, we have since fixed this problem. Finance will keep a calendar of all reporting requirements and check in prior to the due date to ensure reports are submitted on time. Name(s) of the contact person(s) responsible for corrective action: Mark C. Mason, CPA, Financial Services Director; Juan G. Guerra, ICMA-CM, CPA, Controller Planned completion date for corrective action plan: April 30, 2023

View Audit 46467

Finding 46423 (2022-002)

Material Weakness 2022

City of Toledo

OH

Reporting Internal Control / Segregation of Duties

The City will enhance its internal controls over reporting and review federal guidance for reporting under the ERA program. 9-30-2023 Melanie Campbell, Interim Finance Director.

View Audit 46466

Finding 46420 (2022-001)

Material Weakness 2022

Lamar Housing Authority

CO

Eligibility HUD Housing Programs Reporting

Management?s Response: Lamar Housing Authority will begin making a copy of what is put in MINC and will check income from the worksheet we get at the beginning of each month before we submit it we will make changes to what was submitted into MINC, this will be a double check of income to make sure ...

Management?s Response: Lamar Housing Authority will begin making a copy of what is put in MINC and will check income from the worksheet we get at the beginning of each month before we submit it we will make changes to what was submitted into MINC, this will be a double check of income to make sure it was entered into MINC correctly.

View Audit 44738

Finding 46374 (2022-037)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TEST AND PROVISIONS - ADP RISK ANALYSIS & SYSTEM SECURITY REVIEW Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 The DHHR utilizes an external service organization for the design, development, implementation, an...

SPECIAL TEST AND PROVISIONS - ADP RISK ANALYSIS & SYSTEM SECURITY REVIEW Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 The DHHR utilizes an external service organization for the design, development, implementation, and operation of the West Virginia Medicaid Management Information System (MMIS). The system furnishes the core MMIS functionality to support the State's Medicaid program, including maintaining provider, member/recipient, and reference/procedure code data, as well as processing and adjudication rules for claims, encounters, and prior authorizations. The system also provides configuration and system management tools to govern access to data, user security, and communications. The system is an object-oriented, rules-based software program that is designed to manage multiple lines of health care business. The system employs a unified relational database that enables efficient use of data and consistent information throughout all applications. The system includes functionality for claims processing and adjudication, provider administration, benefit plan and policy administration, member administration, and medical service authorization management. The service organization has developed a variety of policies and procedures including related control activities to help ensure their objectives are carried out and risks are mitigated. The control environment includes control objectives related to claims input (hard copy/paper claims and electronic claims); claims processing; claims payment; file maintenance (provider master file, recipient master file, and procedure codes); logical access (passwords and authentication, adding and modifying user access, terminating user access, access to privileged functions, and access review monitoring); change management; production scheduling; and backup procedures. Control activities are performed at a variety of levels throughout the organization and at various stages during the relevant business or information technology process. As expected, controls may be preventive or detective in nature and may encompass a range of manual and automated controls, including authorizations, reconciliations, and information technology controls. The service organization has a formal program in place to review and update the service organization's policies and procedures on at least an annual basis. Any changes to the policies and procedures are reviewed and approved by the service organization?s management and communicated to its employees. As indicated in the Condition section of this finding, the DHHR obtains a Service Organization Controls (SOC) 1 Type 2 report from its service organization on an annual basis. For the period ended June 30, 2022, although the DHHR did not formally document its review of the service organization?s SOC 1 Type 2 report, the DHHR did indeed review it and can hereby confirm that the service organization provided an assertion about the fairness of the presentation of the description and the suitability of the design and operating effectiveness of the controls to achieve the related control objectives stated in the description. The service organization was responsible for preparing the description and assertion, including the completeness, accuracy, and method of presentation of the description and assertion; providing the services covered by the description; specifying the control objectives and stating them in the description; identifying the risks that threaten the achievement of the control objectives; selecting the criteria stated in the assertion; and designing, implementing, and documenting controls that are suitably designed and operating effectively to achieve the related control objectives stated in the description. The DHHR can also hereby confirm that the service organization?s service auditor conducted the examination in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards required the service auditor to plan and perform the examination to obtain reasonable assurance about whether, in all material respects, based on the criteria in the service organization?s assertion, the description is fairly presented, and the controls were suitably designed and operating effectively to achieve the related control objectives stated in the description throughout the specified period. Finally, the DHHR can hereby confirm that in the service auditor?s opinion, in all material respects, based on the criteria described in the service organization?s assertion: 1) the description fairly presented the West Virginia MMIS that was designed and implemented throughout the period July 1, 2021 to June 30, 2022; 2) the controls related to the control objectives stated in the description were suitably designed to provide reasonable assurance that the control objectives would be achieved if the controls operated effectively throughout the period July 1, 2021 to June 30, 2022 and the subservice organizations and the user entity applied the complementary controls assumed in the design of the service organization?s controls throughout the period July 1, 2021 to June 30, 2022; and 3) the controls operated effectively to provide reasonable assurance that the control objectives stated in the description were achieved throughout the period July 1, 2021 to June 30, 2022 if the complementary subservice organizations and the user entity controls assumed in the design of the service organization?s controls operated effectively throughout the period July 1, 2021 to June 30, 2022. The DHHR is of the opinion that it is in compliance with 45 CFR 95.621 since it receives and reviews the SOC 1 Type 2 report from the service organization and since the report documents that the service organization establishes and maintains a program for conducting periodic risk analyses to ensure appropriate, cost-effective safeguards are incorporated into new and existing systems or whenever significant system changes occur. However, the DHHR recognizes the concern expressed within this finding, in that the DHHR does not include the SOC 1 Type 2 report as part of its own policies and procedures for ADP security over the MMIS. To enhance its controls, the DHHR will implement a policy and related procedures to document MMIS compliance with 45 CFR 95.621. The procedures will include but not be limited to a requirement to review and approve the SOC 1 Type 2 report from the MMIS service organization and document the review and approval process (e.g., for such matters as the service organization?s assertions, descriptions of its systems and controls, control objectives, and related controls, and the service auditor?s description of tests of controls and results). The anticipated date for implementation of the policy and related procedures is September 30, 2023, which is prior to the anticipated date for receipt of the next SOC 1 Type 2 report from the service organization.

View Audit 40967

Finding 46373 (2022-036)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services (BMS) collected and reviewed the audited financial statements from the m...

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services (BMS) collected and reviewed the audited financial statements from the managed care organizations (MCOs); however, review and approval of the financial statements were not documented. The BMS is establishing a process to document this approval process for the next reporting period. The BMS also understands the requirements related to 42 CFR 438.602(e). These requirements became effective for contracts starting on or after July 1, 2017. The BMS acknowledges their responsibility to audit the financial and encounter data for the MCOs no less than once every three years and to post the results on the state website. The BMS has previously relied upon agreed-upon procedures engagements conducted by an independent auditor to support the accuracy, truthfulness, and completeness of the MCO reported encounter and financial data. For the reporting period ended June 30, 2022, the BMS has contracted and engaged with an MCO oversight and actuarial vendor to conduct the independent audits and post them to the state website upon completion and approval by the BMS; however, as of the date of this report, the audit has not yet been completed by the vendor. For future reporting periods, the BMS intends to retain an MCO oversight and actuarial vendor to conduct the required independent audits to ensure continued compliance with 42 CFR 438.602(e).

View Audit 40967

Finding 46372 (2022-035)

Significant Deficiency 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

SPECIAL TESTS AND PROVISIONS ? UTILIZATION CONTROL AND PROGRAM INTEGRITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services plans to leverage existing case closure policies and procedu...

SPECIAL TESTS AND PROVISIONS ? UTILIZATION CONTROL AND PROGRAM INTEGRITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778, ARRA ? 93.778 The DHHR Bureau for Medical Services plans to leverage existing case closure policies and procedures and implement an updated case tracking system which, through workflow rules, will make the closure process and requirements explicit so the system will not permit closures without record of all required information and manager approval. This new system is being implemented as part of an ongoing data warehouse project and should be in place by April 1, 2023.

View Audit 40967

Finding 46358 (2022-039)

Material Weakness 2022

State of West Virginia

WV

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 For the one report that had an incorrect subaward amount, the subrecipient?s DUNS number was mistakenly keyed into the FSRS system as the subaward amount. For the one report that was not sub...

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 For the one report that had an incorrect subaward amount, the subrecipient?s DUNS number was mistakenly keyed into the FSRS system as the subaward amount. For the one report that was not submitted timely, the DHHR awarded the grant to the subrecipient on December 5, 2021. The amount of the subaward was $220,000. The identifying information for the subaward was submitted to FSRS.gov on January 30, 2022, which was timely. On June 2, 2022, the DHHR approved a change order to the subaward, which increased the amount of the subaward to $502,131. Accordingly, the FSRS report was reopened on July 29, 2022, whereby the subaward amount was increased to $502,131. However, the report was not actually submitted within the FSRS system until November 8, 2022. Both of these instances were due to human error and were passed on to the appropriate offices within the DHHR. The staff member in charge of the FFATA reporting for the DHHR was made aware of the instances in an effort to improve controls and has corrected the reports in FSRS.

View Audit 40967

Finding 46355 (2022-033)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Starting July 1, 2023, WV CHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring proce...

SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Starting July 1, 2023, WV CHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring processes. This consolidation will ensure that audited financial reports are submitted by the managed care organizations and documentation of review and approval is maintained.

View Audit 40967

Finding 46353 (2022-031)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? MEDICAL LOSS RATIO (MLR) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 Starting July 1, 2023, WVCHIP will be included in the Medicaid managed care contracts and will be consolida...

SPECIAL TESTS AND PROVISIONS ? MEDICAL LOSS RATIO (MLR) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, ARRA 93.778 Starting July 1, 2023, WVCHIP will be included in the Medicaid managed care contracts and will be consolidated into Medicaid's oversight and monitoring processes. This consolidation will ensure that documentation of review and approval of MLR reporting is maintained.

View Audit 40967

Finding 46334 (2022-028)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The Income and Eligibility Verification System (IEVS) provides the DHHR Bureau for Family Assistance (the Bureau) with sources...

SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The Income and Eligibility Verification System (IEVS) provides the DHHR Bureau for Family Assistance (the Bureau) with sources of information for use in determining eligibility and the amount of the benefit for applicants and recipients. Procedures established to assist in the prevention of fraud and abuse in the form of computer matches are utilized. The social security number of the applicant or recipient is matched against the files from the West Virginia Bureau of Employment Programs, the Internal Revenue Service, and the Social Security Administration (SSA). The State Online Query (SOLQ) provides direct access to SSA?s databases. Information received includes SSN verification; Supplemental Security Income (SSI); and Retirement, Survivors, and Disability Insurance (RSDI) details. Requests can be made only for individuals known to the eligibility system within the previous five years. The Bureau?s Policy Unit will collaborate with the Bureau?s Division of Professional Development to create a more detailed and precise training for the IEVS System. The blackboard platform will allow supervisors to track workers that have completed the training. The anticipated date for completion is June 30, 2023. Furthermore, the Policy Unit will send out various IEVS Policy Reminders and will work to revise the IEVS User Guide.

View Audit 40967

Finding 46333 (2022-027)

Material Weakness 2022

State of West Virginia

WV

Special Tests & Provisions Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The WV WOR...

INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558 The WV WORKS Policy Unit within the DHHR Bureau for Family Assistance will continue to send out reminders and Sanction Flowchart/Desk Guides to staff. The bureau?s Policy Unit will work with the bureau?s Division of Professional Development regarding the continued use of Blackboard Courses and Virtual Training. The WV WORKS Council will add a ?Sanction Workshop? to Payment Accuracy Conferences; the anticipated date for completion is August 31, 2023. Finally, the Policy Unit will continue to review RAPIDS Management Reports monthly regarding third level sanctions to ensure the sanctions are being sent to the Policy Unit for review and approval.

View Audit 40967

Finding 46291 (2022-023)

Material Weakness 2022

State of West Virginia

WV

Questioned Costs Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

ALLOWABILITY Bluefield State University, Glenville State University, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Bluefield State University (BSU) response P425F200727 $19,882?BSU agrees with the finding that these were routine maintena...

ALLOWABILITY Bluefield State University, Glenville State University, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Bluefield State University (BSU) response P425F200727 $19,882?BSU agrees with the finding that these were routine maintenance costs that, which would mitigate the spread of COVID, would have been incurred by the University in any event. BSU has put in place procedures to review all future use of funds to be certain that are specifically related to COVID mitigation. P425J200063?BSU believes the questioned costs in this finding were allowable. At the time BSU made the draw for the costs, BSU based the decision on FAQ #23 and used the definition of minor remodeling. This wall is within a previously completed functioning building, and does not structurally alter the building, therefore, BSU deemed it to be remodeling. Due to the overall cost of the wall in comparison to the market value of the building BSU deemed it to be minor. As stated in 34 CFR ? 77.1, ?[m]inor remodeling means minor alterations in a previously completed building? and also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building.? The response to Question #24 of the FAQ provides some additional guidance and specific examples of permissible ?minor remodeling? that may be paid for with HEERF grant funds. The remodeling in this case was very similar to the examples of permissible minor remodeling provided in the FAQ. Obtaining the hospital building permitted BSU to offer on-campus housing in a portion of the hospital that was converted into student dormitories. Another part of the building remained in use as a hospital. HEERF funds were used to construct a wall between the dormitory area and the part of the building being used as an Emergency Room. As a result, the construction of the wall in question was ?for purposes associated with the coronavirus? and should be viewed as an eligible HEERF expenditure. The related plumbing and electrical work should also be viewed as a permissible expenditure given the reference in the response to FAQ #24 to ?the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building.? As indicated previously, at the time the decision to use HEERF fund for the construction of the wall, prior approval was not required. The project in question can be fairly characterized as a minor alteration in a previously completed building for the purposes of preventing the spread of COVID-19. For all of the reasons discussed above, BSU respectfully maintains that the construction of the wall in question and the related electrical and plumbing work should be viewed as an eligible expenditure. P425E200618: BSU believes awards were made in good faith and according to the regulations, as described below. However, BSU proposes the following corrective action plan to mitigate the issue. BSU used $305,191 of institutional funds to make emergency grants to students that the auditors agree meet the definition in the FAQs. These grants were based solely on the number of credits the students were enrolled in during the term or were to pay for books for students who requested assistance. BSU proposes to reimburse the Institutional funds for those grants from the above amount drawn. That would leave a balance of $1,291,079 in dispute and free up those Institutional funds for upcoming COVID related expenses. Additionally, BSU has HBCU funds that are unspent as of the date of this response. BSU proposes to reimburse the remaining balance of $1,291,079 from the HBCU funds. BSU believes these are valid expenses for HBCU funds. That would return those funds to the Student portion, which would allow BSU to make additional emergency payments to students before the funds expire on June 30, 2023. These questions costs were for grants to students who lived in surrounding counties outside of West Virginia who were given waivers for the tuition above the University?s in-state rate, to student athletes and those with certain levels of academic achievement. In addition to the grants noted above, BSU used the Student Portion of HEERF funds to provide emergency funds to all students, based only on their part-time or full-time status. BSU relied on FAQ #s 11, 12 and 13 in determining that expending the funds was within the proper guidelines. For example, the funds were used for the students? cost of attendance and electronic or written authorization were received to use the funds to satisfy students? account balances. Nearly half of those who received the grants in question were Pell eligible (277 out of 600, or 46%). Similarly, approximately 46.9% of the funds spend on grants in these three categories went to Pell eligible students. Therefore, BSU believes that students with exceptional need were appropriately prioritized in awarding these grants. Out-of-state students faced an added financial burden based on the added cost of out of state tuition. Grants to those students to assist with that cost were not linked to any of the factors identified in the response to FAQ #12 as a basis for determining that an institution failed to prioritize emergency financial grants to students with exceptional need. Grants to out-of-state students were just one avenue of distributing HEERF funds to students, who were free to pursue other avenues of funding. As indicated above, BSU used the Student Portion of HEERF funds to provide emergency funds to all students, based only on part-time or full-time status, which given the high percentage of Pell eligible students attending BSU, reached many students with exceptional need. Due to the high proportion of Pell eligible students who received the grants in question and the high costs faced by the out-of-state students, BSU believes that the grants to out-of-state students did not demonstrate a failure to prioritize students with exceptional need. With respect to students who received grants who participated in athletic programs or demonstrated certain levels of academic performance, BSU notes again the group in question contained a high proportion of Pell eligible students. Funds were available through other means to students other than those participating in athletic programs or demonstrating high levels of academic performance (including but not limited to the out-of-state students discussed above or the emergency funds made available to all students based only on full-time or part-time status that were provided using the Student Portion of HEERF funds). Academic performance or athletic participation were not a prerequisite to receiving any assistance at all, but rather two ways to access assistance. Viewing efforts to provide aid to students as a whole, BSU does not believe that the distribution of HEERF funds demonstrated a failure to prioritize emergency financial aid grants to students with exceptional need. Glenville State University (GSU) response To ensure compliance with all federal reporting guidelines, existing federal time and effort calculation guidelines, along with relevant internal control policies and procedures, will be saved to a shared drive or other location to which the necessary personnel have access. As a best practice, primary consideration will be given for the usage of detailed time sheets or time logs being kept for each GSU employee whose time or effort is partially or wholly allocated to federal grant-related activity. These time sheets/time logs will include the percentage of time spent working on grant-related activities, the percentage of time spent working on non-grant university-related activities, a general description of activities performed for the grant related activity, and the total number of hours worked each week. Time sheets/logs will be reviewed and approved regularly by the grant-funded employee, the employee?s supervisor, and the Grants Compliance Director or designee. In cases for which the time sheet method is not deemed practical to be employed, the Chief Financial Officer or designee will draft a memo that provides a detailed explanation and justification of the method used for calculating time and effort. This memo will be signed by the Chief Financial Officer and the Director of Grants Compliance. On a quarterly basis, the Controller or Chief Financial Officer and Director of Grants Compliance will meet to ensure the relevant documented time and effort matches the corresponding draw down amounts. Mountwest Community and Technical College (MCTC) response Effective February 2022, MCTC enhanced policies and procedures to ensure formal approval and documentation of expenditures for HEERF funds is retained to ensure compliance.

View Audit 40967 Questioned Costs: $1

Finding 46290 (2022-022)

Material Weakness 2022

State of West Virginia

WV

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Communit...

REPORTING Fairmont State University, West Virginia State University, Bluefield State University, West Virginia Northern Community College, West Liberty University, Southern West Virginia Community and Technical College, Pierpont Community and Technical College, Concord University, Mountwest Community and Technical College, and Glenville State University Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Fairmont State University (FSU) response In regard to the Annual Reporting of HEERF, the Controller will work with the Financial Reporting Manager to ensure the annual data is accurate and reflects the data reported on the quarterly reporting for the same period. The Controller will perform data entry of all required fields in the annual submission website. Once complete, an email will be sent to the CFO for final review and approval. The CFO will provide email correspondence that the review is complete and the reporting is approved for submission. The CFO will submit the annual report via the reporting website. This action was implemented January 2023. West Virginia State University (WVSU) response WVSU developed and documented an internal control procedure to ensure compliance of HEERF Reporting. This procedure includes a dual review and sign off process by Business and Finance before the report is posted to WVSU?s website. This review includes ensuring accurate forms are being used for reporting. Additionally, screen captures are saved to provide a date/timestamp of when the report was made public. The control was implemented on or before July 1, 2022. Bluefield State University (BSU) response BSU has strengthened internal controls over reporting of HEERF funds to assure that the posting to the University website in a timely manner is documented in writing. BSU posted all reports to the University website on or before the filing deadline. However, we did not receive written documentation from our IT department to document the timely posting. We have revised our internal control procedures to ensure that that we receive and retain documentation of the posting date. BSU inadvertently used incorrect terminology to describe some of the emergency grants to students made from the Student Portion of HEERF funds. The reports selected for testing were for the Student Portion of funds that was reported in a narrative format. The revised reporting form issued by the Department of Education combines the reporting of Student, Institutional and HBCU funds on one standard form. This will eliminate these types of errors in subsequent reporting. West Virginia Northern Community and Technical College (WVNCC) response WVNCC is aware to include the total amount of grants distributed, the estimation of students to receive a grant and the total amount of students to receive the grant from the calculations used to issue Emergency Financial Aid Grants. In addition to reporting the method used to determine award amounts to students prior to the awards being disbursed, WVNCC will also include the method used in future reporting. As an added layer of review, WVNCC will include a third report reviewer from Student Accounts to verify the number and dollar amount of awards disbursed to be included in the report. This action was implemented in January 2023. West Liberty University (WLU) response As of January 2023, federal drawdowns are reconciled and reviewed prior to the drawdown. The signature of the Controller or CFO is on each drawdown with the date of review and approval. The drawdown is then completed usually on the same date as the review and approval. Southern West Virginia Community and Technical College (SWVCC) response SWVCC has enhanced its procedures surrounding the preparing, updating, and reviewing of quarterly and annual reports for the HEERF Education Stabilization Fund (and all other federal awards). The information utilized to prepare the reports is now dated and saved for future reference. The individual compiling the report documents the date the report is completed and submits it to the reviewer. The reviewer documents the date of review and any adjustments made to the report. The review is completed before the report is posted to the institution?s website and all documentation will be maintained for audit review. These procedures are in place as of January 2023. Pierpont Community and Technical College (PCTC) response PCTC?s staff and administration have reviewed the reporting requirements for HEERF funding to ensure quarterly and annual reports are accurate and timely. All staff involved in the reporting process, which includes the offices of Financial Aid, Registrar and Finance, have been directed to document and retain all source data used in the reporting process. A documented review process was put in place in October 2022 to ensure review by a supervisor and a final review by the Vice President of Finance and Administration/Chief Financial Officer or the Comptroller. Evidence of the review process is demonstrated through sign offs and/or e-mail communications. Concord University (CU) response Beginning with the December 2022 quarterly reporting, the coordination and approval of all reports will continue to be documented electronically. Additionally, the level of review/approval for the generated reports prior to posting will also be documented, and all work orders requesting the public posting of approved reports will include a cited reminder of the federal posting deadline for grant compliance. This additional information in the requested work order will ensure all parties involved are aware of and meet the required posting deadline. These steps were taken for the December 2022 Institutional Portion (CFDA #84.425F) quarterly reporting and resulted in a timely posting. The Student Aid Portion (CFDA #84.425E) final reporting occurred during fiscal year 2022. Mountwest Community and Technical College (MCTC) response For student reporting ? Q4 FY2021 and Q3 FY2022 there were no student reports prepared for these quarters. MCTC submitted OMB Control Number 1840-0849 with no expenditures reflected for HEERF I, II, or III Student Portion for FY21 Quarter 4 and FY 22 Quarter 3. All funds were fully expended by the end of FY 22 Quarter 2. Although there were no HEERF Student Portion funds expensed during the Quarters in question, MCTC has acknowledged that the language on the website should have been updated to disclose all funding as awarded and final. As a response to the finding, MCTC will develop a Quarterly Reporting schedule for posting on the website to capture all awarding activity from HEERF I, II, and III from point of initial receipt of HEERF funds through the grant end period, June 30, 2023. For Institutional Reporting ? Q4 FY2021 institutional report was not posted timely within the 10-day reporting requirement. This occurred before the PY corrective action plan was implemented. A corrective action plan was submitted on February 17, 2022 and all subsequent quarterly reports have been submitted timely. Glenville State University (GSU) response GSU implemented and strengthened internal controls surrounding the reporting for both HEERF II and III in February 2022. GSU has created and filled the position of Director of Grants Compliance. This new Director has direct oversight and assurance of GSU?s compliance with all grant reporting requirements. The Director will prepare and maintain a ?Master? checklist for all grants received by GSU. The checklist will be monitored and updated as reporting or compliance steps are met by the Director. The Director will coordinate with the relevant personnel with reporting or compliance responsibility over the grant to ensure the compliance expectations are met timely.

View Audit 40967

Finding 46287 (2022-025)

Significant Deficiency 2022

State of West Virginia

WV

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number 84.425C, 84.425D, 84.425R, 84.425U Program management will implement policies and procedures to ensure that Transparency Act Reporting is conducted with proper reviews. In order to comply with the Federal Funding Acc...

TRANSPARENCY ACT REPORTING Department of Education (DOE) Assistance Listing Number 84.425C, 84.425D, 84.425R, 84.425U Program management will implement policies and procedures to ensure that Transparency Act Reporting is conducted with proper reviews. In order to comply with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202(a) of the Government Funding Transparency Act of 2008 (Pub. L. No. 111-252), that relate to sub-award reporting, the DOE Office of Internal Operations will work with each awarding office to ensure the sub-awards have been thoroughly reviewed and signed before reporting each month. This will comply with 2 CFR 200.303 which requires an entity to "maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award". The timeline for the development and initiation of this process (barring any unforeseen system limitations) is tentatively set for July 1, 2023.

View Audit 40967

Finding 46286 (2022-021)

Material Weakness 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

MAINTENANCE OF EFFORT Department of Education (DOE) Assistance Listing Number 84.425C/84.425D/84.425R/84.425U DOE submitted a waiver request in June 2022 and is currently working with the U.S. Education Department to obtain a waiver for Maintenance of Effort for FY22. DOE is also working with the ...

MAINTENANCE OF EFFORT Department of Education (DOE) Assistance Listing Number 84.425C/84.425D/84.425R/84.425U DOE submitted a waiver request in June 2022 and is currently working with the U.S. Education Department to obtain a waiver for Maintenance of Effort for FY22. DOE is also working with the Office of the Governor and Legislative Leaders to review compliance for the 2023 fiscal year.

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Finding 46234 (2022-017)

Significant Deficiency 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY Fairmont State University and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU...

SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY Fairmont State University and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response FSU entered into a contract with Wolf & Company to perform an external risk assessment for our systems in 2021 but was not completed due to staffing changes until 2022. The external risk assessment was received from Wolf in June 2022. The report and its suggestions were immediately reviewed and approved. This action will be implemented in January 2023 for fiscal year 2023 and will be implemented each July, starting with July 2023, hereafter. It was not understood that annual reviews needed to occur at the beginning of each fiscal year until this finding was received. Pierpont Community and Technical College (PCTC) response In December 2022 and January 2023, PTCT developed the following policies and procedures, which also detail internal controls, relative to the Gramm-Leach-Bliley Act and student information security. ? Access to Security Controlled Spaces Policy ? Anti-Virus Policy ? Backup and Recovery Policy ? Change Management Policy ? Computer Disposal Policy ? Computer Security Policy ? Data Security Policy ? IT Firewall Policy ? IT Incident Response Policy ? System Update Policy ? Mobile Device Use Policy ? Remote Access Policy ? Risk Assessment Policy ? Banner Document Procedure ? Banner Security Procedure ? Argos Access Procedure ? Active Directory Security and User Creation ? National Student Loan Clearinghouse Enrollment Submission Procedure ? National Student Loan Clearinghouse Graduate Only Submission Procedure ? Nelnet Refunds Procedure ? Risk Assessment Procedure Risk assessments will now be performed two times a year and will follow the Risk Assessment Procedure. This procedure also incorporates all policies, procedures, and internal controls as the framework for the ensuring of student information security.

View Audit 40967

Finding 46232 (2022-015)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS - VERIFICATION Bluefield State University, Fairmont State University, and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Bluefield State University (BSU) response...

SPECIAL TESTS AND PROVISIONS - VERIFICATION Bluefield State University, Fairmont State University, and Pierpont Community and Technical College Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Bluefield State University (BSU) response Effective January 2023, after all calculations are made and checklists are completed the files will be reviewed by another counselor for accuracy. This reviewer will sign off on the file and checklist that it has been reviewed and no errors were found or recalculation needed. Both the preparer and the reviewer will sign off and date the checklist. Fairmont State University (FSU) response Controls were put into place in 2020-2021 to address the additional review of the verification process once the initial review was completed. FSU found that through some reporting and timing that the additional review did not occur for all students. FSU will implement a weekly review with a comprehensive review monthly to ensure no students are missed through the additional review process in February 2023. Pierpont Community and Technical College (PCTC) response Staff members have been, and will continue to be, prompted to print, scan and keep all documentation pertaining to verifications. In these two cases, the counselor did not print the Confirmation page that displays upon completing V4 & V5 verifications in Central Processing System (CPS) and did not follow the flow of placing the verification packet in the appropriate location for second review. PCTC has reviewed policies and procedures and made a slight modification. Beginning with the 22/23 aid year, the Financial Aid Administrator (FAA) brings the completed verification packet to the Director of Financial Aid. The Director then determines who will complete the second review. The second review can be completed by either the Director of Financial Aid, the Assistant Director of Financial Aid or another qualified FAA. Once completed and signed off, the verification packet is place into the permanent individual student?s file.

View Audit 40967 Questioned Costs: $1

Finding 46230 (2022-013)

Significant Deficiency 2022

State of West Virginia

WV

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Fairmont State University, West Virginia State University, and West Virginia School of Osteopathic Medicine Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FS...

FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Fairmont State University, West Virginia State University, and West Virginia School of Osteopathic Medicine Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response As of January 2023, the Financial Reporting Manager will complete Part II of the Fiscal Operations Report and Application to Participate (FISAP) submission. The Controller will review and compare with audited financial statements to ensure the correct amounts are recorded prior to approval and submission by the institution. West Virginia State University (WVSU) response This finding was a result of inaccurate reporting. The dollar amounts used for tuition and fees in the original calculation were incorrect. The supporting documentation was updated after submission of the FISAP to include correct numbers. To prevent this from occurring in the future, a dual review will be required for all reporting data. The Office of Financial Aid and Scholarships will verify the Federal Work-Study (FWS) and Supplemental Education Opportunity Grant (SEOG) fund allocations are identified correctly on the FISAP, in regard to transfer of funds, to accurately reflect the allotted fund amounts and amounts paid to student accounts in Banner. These changes were made effective March 2022 and reflected in the FY22 FISAP. West Virginia School of Osteopathic Medicine (WVSOM) response Internally generated reports used to prepare the FISAP from WVSOM?s management system have been modified to ensure accuracy and clarity of the data. Procedures are in place for a secondary review of the report prior to submission.

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Finding 46227 (2022-010)

Significant Deficiency 2022

State of West Virginia

WV

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

REPORTING State of West Virginia (WV) Assistance Listing Number 21.027 Going forward, WV will ensure that all data requested for calculations related to the revenue replacement calculation or any other aspect of reporting to the Department of Treasury is independently reviewed to ensure the data u...

REPORTING State of West Virginia (WV) Assistance Listing Number 21.027 Going forward, WV will ensure that all data requested for calculations related to the revenue replacement calculation or any other aspect of reporting to the Department of Treasury is independently reviewed to ensure the data used is aligned with the parameters needed for reporting (e.g. all transactions fall within the proper dates, appropriate accounts and cost categories are included, etc.) prior to use for such calculations. Analytical procedures will be used to compare data used to other financial reports to ensure reasonableness.

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Finding 46226 (2022-009)

Material Weakness 2022

State of West Virginia

WV

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

SPECIAL TESTS AND PROVISION ? UI PROGRAM INTEGRITY - OVERPAYMENTS Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 WWV will provide training to all Unemployment Insurance claim staff by March 2023 and review procedures related to the establishment of overpayments.

View Audit 40967 Questioned Costs: $1

Finding 46225 (2022-008)

Material Weakness 2022

State of West Virginia

WV

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

INTERNAL CONTROLS OVER INFORMATION TECHNOLOGY Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 As of November 2022, WWV began and will continue to develop the processes for periodic review of user accounts for ABPS, UC Tax, and wvOASIS. Processes will include documen...

INTERNAL CONTROLS OVER INFORMATION TECHNOLOGY Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 As of November 2022, WWV began and will continue to develop the processes for periodic review of user accounts for ABPS, UC Tax, and wvOASIS. Processes will include documenting termination of employees timely to the West Virginia Office of Technology (WVOT) to remove network access or within the organization to remove access to IT systems at the time of exit. WVOT will be adding features to Ivanti (WVOT service portal) so that WWV may download account management activity for validation, tracking, and review. WWV participates in Disaster Recovery operations when the WVOT holds them. Since WWV is covered by WVOT, WWV cannot reasonably procure a separate process for disaster recovery testing without the assistance and involvement of WVOT.

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Finding 46221 (2022-005)

Material Weakness 2022

State of West Virginia

WV

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Community Development Block Grant Program (CDBG) Assistance Listing Number 14.228, COVID-19 14.228 Since the COVID pandemic occurred, the West Virginia Community Advance and Development office (CAD) experienced a high personnel turnover rate. As a result, CAD experienced a delay in implementing th...

Community Development Block Grant Program (CDBG) Assistance Listing Number 14.228, COVID-19 14.228 Since the COVID pandemic occurred, the West Virginia Community Advance and Development office (CAD) experienced a high personnel turnover rate. As a result, CAD experienced a delay in implementing the corrective action plan related to this finding. During the last 30 days, CAD has completed Federal Funding Accountability and Transparency Act (FFATA) training and has designated the personnel to the FFATA reporting process. Additionally, CAD has developed a checklist related to these grant awards which includes the FFATA system entry submission. These policies and procedures were implemented February 1, 2023.

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Finding 46216 (2022-004)

Material Weakness 2022

State of West Virginia

WV

Subrecipient Monitoring Reporting School Nutrition Programs § 200.303

Department of Education (DOE) Assistance Listing Number 10.553, 10.555, 10.556, 10.559, 10.582 Program Management will implement policies and procedures to ensure Transparency Act reporting is conducted with proper reviews and timely submissions. In order to comply with the Federal Funding Account...

Department of Education (DOE) Assistance Listing Number 10.553, 10.555, 10.556, 10.559, 10.582 Program Management will implement policies and procedures to ensure Transparency Act reporting is conducted with proper reviews and timely submissions. In order to comply with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202(a) of the Government Funding Transparency Act of 2008 (Pub. L. No. 111-252), that relate to sub-award reporting, DOE is working with the Child Nutrition Claiming Software vendor to create a report that will be run on the first of each month. Staff from the Office of Internal Operations and Office of Child Nutrition will be assigned to generate, enter, and submit data as required by the Transparency Act. To meet the timelines for reporting as established by the Transparency Act, the report will pull all activity for the prior month including all original reimbursement claims, as well as amendments that occur in that month to reimbursement claims that were previously reported. Prior to submission of the data, a report of its contents will be reviewed and approved by either the Child Nutrition Program Director or the Director of Internal Operations. Once the data is approved, it will be submitted. The timeline for development and initiation of this reporting process (barring any unforeseen system limitations) is tentatively set for July 1, 2023.

View Audit 40967

Finding 46209 (2022-003)

None 2022

State of West Virginia

WV

Eligibility Internal Control / Segregation of Duties

Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561 The DHHR Bureau for Family Assistance (the Bureau) analyzed the condition that led to this finding. The emergency supplement in question was paid on the initial month of SNAP issuance. However...

Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561 The DHHR Bureau for Family Assistance (the Bureau) analyzed the condition that led to this finding. The emergency supplement in question was paid on the initial month of SNAP issuance. However, these supplements were not to be based on the initial or prorated months of SNAP benefits. Per the U.S. Department of Agriculture, Food and Nutrition Service (FNS), emergency supplements were not to be initiated until the second month of SNAP issuance (i.e., the month following active SNAP approval). The emergency supplement allotments will end February 28, 2023. If the FNS instructs the Bureau to issue emergency supplement allotments for the SNAP Program beyond February 28, 2023, the Bureau will develop a blackboard course with video to ensure that all workers are trained on the procedures and policy. The blackboard platform has the capability to track who has completed the training which will ensure supervisors can determine who has or has not completed the required training.

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Corrective Action Plans

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