Corrective Action Plans

ALLOWABILITY OF EXPENDITURES Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 Microdyn OPPS quarterly updates for Pricer and Editor Dynamic Link Libraries (DLLs) are commonly received mid-month of the first month in the quarter after the Centers for Medicare and Medicaid Services releases quarterly updates. During 2022, releases occurred on January 15, April 16, July 16, and October 19. Although updates to the DLL were completed timely throughout the year, claims sampled for the audit fell into the periods of delay between the first day of the quarter and the updates to the DLL. Procedures are in place to reprocess any affected claims once the quarterly updates have been uploaded into the system. However, there was an interruption in the procedure to reprocess claims after the quarterly updates were uploaded to the claims processing system. Corrective action has already been implemented that includes automatically opting and populating the "reprocess claims" flag in the Request Management System (RQMS) when the Microdyn OPPS updates are entered to work. (The RQMS is the system used to enter and manage work orders for the Medicaid Management Information System.) Claims processing staff at the fiscal agent have also entered calendar reminders to reprocess claims as necessary after the OPPS quarterly updates are processed. All affected claims including claims sampled for the Single Audit were reprocessed and paid from mid-December 2022 through mid-January 2023.

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.

SPECIAL TESTS AND PROVISIONS ? PROVIDER ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.767 For the population related to provider eligibility, the auditors were provided a population/report of active providers, which the auditors used to select their sample. To determine if a provider is enrolled or terminated, the provider record must be accessed, and the enrollment effective date and termination effective date must be viewed. The termination dates on the provider record are accurate in HPAS (claims processing/payments system), as the claims processing system refers to the dates on the provider record. However, radio buttons in HPAS, system do not accurately reflect active enrollment. Claims submitted by terminated providers (providers with no active enrollment) are denied. The processing system looks for a termination date on the provider record and denies claims for providers with termination dates. No payments were made to providers with terminated enrollment and no claims payment errors were identified. Two other errors identified resulted from human error. One provider was erroneously indicated as enrolled with CHIP but had no CHIP contract attached in the system, and one provider did not receive an approval letter. Continuing training will be conducted with provider enrollment staff to ensure plan relationships are removed if not applicable and that letters are manually generated when the application is also manually reviewed.

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.

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.

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.

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.

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.

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.

REPORTING West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current RSA-17 approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of report approval is maintained within our records.

CASH MANAGEMENT West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current cash approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of cash draw approval is maintained within our records.

SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS Pierpont Community and Technical College (PCTC) 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 PCTC?s standard procedure for disbursement letters is to have the Information Systems Specialist (ISS) provide letters for review to the Director of Financial Aid before mailing. This was either not done by the ISS or overlooked by the Director. The process has been reviewed and communicated to the current Information Systems Specialist as well as the Assistant Director of Financial Aid. The Assistant Director of Financial Aid is authorized to review letters in the absence of or instead of the Director. This action was implemented January 2023.

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.

SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION Pierpont Community and Technical College and West Virginia State University 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 Pierpont Community and Technical College (PCTC) response Beginning July 1, 2022, PCTC has updated the monthly reconciliation process. The Direct Loan School Account Statement (DLSAS) reports from Common Origination and Disbursement (COD) are downloaded by the 10th of each month, as before, by the Information Systems Specialist (ISS). The reports are now provided to the Assistant Director of Financial Aid (Asst.) and then reconciled to both Banner paid and COD approved Direct Loan disbursements. Reports verifying reconciliation are then completed and saved by the Assistant Director of Financial Aid and reviewed by the Director of Financial Aid for completion and accuracy. PCTC will maintain the documentation of the DLSAS statements each month and the reconciliation report along with evidence of said review. West Virginia State University (WVSU) response After each weekly disbursement, the Financial Aid Technician requests a Year-to-Date SAS Disbursement Detail on Demand Report from COD. The report is compared with the disbursement data within Banner and a COD/Banner Comparison Report is generated. The comparison report is sent to the Associate Director of Financial Aid and Director of Financial Aid to correct and document any discrepancies and if necessary, refers to the monthly DLSAS reports to verify resolution to any found discrepancies. The monthly DLSAS report is reviewed each month by the Director of Financial Aid to confirm consistency between fund disbursement and drawdownsreturn of payments by the Fiscal Office. The Director of Financial Aid and Business and Operations Manager both sign off weekly confirming accuracy. Effective August 2022, policies and procedures have been updated so any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

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.

FINANCIAL REPORTING Pierpont Community and Technical College and West Virginia State University 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 Pierpont Community and Technical College (PCTC) response PCTC?s Assistant Director of Financial Aid (Asst.) will take screen captures of both Banner and the Common Origination and Disbursement (COD) for a monthly reconciliation of the Federal Pell Grant program. Screen captures will be printed, and comparisons will be made by the Asst. All necessary adjustments will be performed to student accounts by the Asst. or Director of Financial Aid (Director) until balanced. The Asst. will sign as an approval on reconciliation documentation and provide to the Director for review and approval. The completed monthly reconciliation information will be retained in the completed reconciliation information file on the shared drive. This process has been implemented as of July 1, 2022. The updated procedure will ensure timely processing of all federal Pell grants to students and updates in the COD system. West Virginia State University (WVSU) response Effective January 2022, WVSU reports information to COD daily. Originations and fund adjustments are imported and exported Monday through Friday for students who meet eligibility requirements by the Financial Aid Technician and the import reports are reviewed by both the Technician and a FA Administrator with corrections being made to any errors and/or rejections. The disbursement process of applying aid to student's accounts occurs weekly throughout the semester after enrollment hours have been confirmed. The disbursement process in Ellucian Banner is completed by the Financial Aid Technician and funds are applied to student's accounts. The Director of Financial Aid proceeds to review the disbursement roster to confirm accuracy of fund sources, fund amounts and enrollment hours after the disbursement process has finished. The Financial Aid Technician sends the disbursement files to COD after the disbursement roster has been reviewed, and loads the response files the following morning. The load response files are reviewed by the Associate Director of Financial Aid and Director of Financial Aid to confirm acceptance. Both the Director of Financial Aid and Business and Operations Manager will sign off weekly confirming accuracy. Policies and procedures were updated August 2022 so that any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

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.

SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING Fairmont State University, Blue Ridge Community and Technical College, Pierpont Community and Technical College, West Virginia State University, and Marshall University 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 The Appeals committee has updated policies and procedures to include the Business Analyst and the Registrar on the email communication list when a retroactive drop that changes enrollment status and/or a retroactive withdrawal is approved. FSU will identify the steps necessary at the National Student Clearinghouse to update the student?s status because this status update will be after the term has ended. FSU has put this plan into action already and will begin cleaning up retroactive drops and withdrawals from here on out. Blue Ridge Community and Technical College (BRCTC) response BRCTC provided training in October 2022 to appropriate staff members on the proper maintenance of record retention. Pierpont Community and Technical College (PCTC) response PCTC?s procedures to Title IV refunds were updated in January 2023 to enhance communication between the Financial Aid and Finance offices to ensure Finance has a copy of the student letter and additional Finance Office staff now have access to the Return to Title IV (R2T4) tracking sheet. The R2T4 tracking sheet is monitored by both the Financial Aid and Finance staff to ensure all refunds are returned within the required 45-day time period. The Director or Assistant Director of Financial Aid also review the return of aid calculations to ensure accuracy. West Virginia State University (WVSU) response Effective January 2022, WVSU utilizes the National, Student Clearinghouse (NSC) to update student?s enrollment and its effects on student?s direct loan and Pell statuses. Thorough edit checks of student data for each semester will be produced by IT on a regular basis. The Office of the Registrar, in coordination with Admissions, Dual Enrollment, and other contributors of student data, will make sure these errors are corrected. Special focus will be placed on resolving these errors before each enrollment file is produced. (Initial Data Integrity, First Check). On or around the 25th of each month, IT will produce the NSC enrollment file. Each time the file is produced, the file will be sent to the Registrar for review to ensure accuracy of the data being pulled from Banner. Registrar sends approval for upload to NSC. (Process Integrity, Second Check) The file will be uploaded to the NSC by IT, ensuring NSC received the appropriate number of records. The data will then be reviewed and any discrepancies in the data, when compared with past data, will be resolved in a timely manner. The Registrar, as the ultimate steward of student enrollment data, has taken full responsibility for resolving NSC errors. The NSC process makes sure these errors are resolved before the data is reported to the NSLDS, it is the responsibility of the Registrar to make sure these are resolved with accurate data. (Data Integrity, Third Check) After resolution of errors, the NSC will perform a final review of data before sending to the National Student Loan Data System (NSLDS). This will be reported on the NSLDS Reporting tab of the Enrollment Reporting screen in the NSC website. If data is satisfactory, the submission will be marked with "Congrats. No Errors!" by the originator "CH" (Clearinghouse). The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fourth Check) The enrollment data is then submitted to the NSLDS. After NSLDS reviews the data, any errors will be reported back through the NSC in the same manner as NSC errors. Resolution of these errors is of special importance and will be given top priority. The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fifth Check) Marshall University (MU) response As approved by Faculty Senate and the President, the 2023 academic calendar has been adjusted so that MU?s summer semester is now one long term with parts of term within it. This calendar revision more closely resembles the current fall and spring semesters. Now that summer is one term with parts of term within, this will allow MU to report enrollment to the National Student Clearinghouse on a multiple report date submission schedule throughout the summer term.

SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS West Virginia State University, Pierpont Community College, Bluefield State University, New River Community and Technical College, and West Liberty University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 West Virginia State University (WVSU) response Effective January 2022, a weekly report of complete withdraw students is generated and an initial review and calculations are performed by a Financial Aid Administrator. A second review of the student?s record and calculations are then completed a second time by the Associate Director of Financial Aid or the Director of Financial Aid. After the second review is complete, the initial reviewer will update the student account accordingly and perform any Return of Title IV (R2T4) funds needed. The second reviewer will confirm that updates are accurate. Both the initial and second reviewer will sign off on R2T4 calculation documentation for the student's file. Pierpont Community and Technical College (PCTC) response Communication between the Financial Aid and the Finance offices will be enhanced to ensure Finance has a copy of the student letter and additional Finance Office staff now have access to the return of Title IV (R2T4) tracking sheet. The R2T4 tracking sheet will be monitored by both the Financial Aid and Finance staff to ensure all refunds are returned within the required 45-day time period. This process was implemented in January 2023. Bluefield State University (BSU) response In January 2023, BSU implemented controls to perform the Return of Title IV (R2T4) withdrawal and calculation to ensure that records comply and that return of R2T4 funds are within the required time frame of 45 days. Controls include the review of ?Permit to Withdraw? forms to ensure they are completed with all signatures of the offices involved and the sign-off of R2T4 calculations. All reviews will occur within the time frame of 45 days by the Interim Financial Director along with Business Office and Accounting. In December 2022, the Interim Financial Aid Director spoke with the Registrar and the Financial Aid Counselor in separate meetings regarding the late submission of withdrawal forms and performing the R2T4 calculations. The Registrar understands they must submit the completed withdrawal forms to the Financial Aid office the same day they are completed by her office. When the forms are received by Financial Aid an R2T4 will be completed within the same week of receipt and sent to the Business Office if a return of Title IV Aid is required. The Business Office will then review the calculations and perform the necessary repayment of Title IV Aid to the Department of Ed, utilizing the refund process through G5 within the required 45 day timeline. All adjustments to the students account will be made within the same time frame. New River Community and Technical College (NRCTC) response The Registrar's office will request the error report from IT. At that point the Registrar?s office will work on correcting the errors on the report. The Registrar?s office will request IT to run the error report again to make sure all errors are clear. Once all errors are clear from the report the Registrar?s office will request IT to send the enrollment report so that it can be submitted to the National Student Clearinghouse (the Clearinghouse). Once the enrollment report is received from IT someone in the Registrar?s office will upload the report in the Clearinghouse. The Registrar?s office will make sure the Clearinghouse report is submitted by the due date and errors sent by the Clearinghouse are corrected in a timely manner. The Registrar's office will run a random selection of 20 students from the National Student Loan Data System (NSLDS) to make sure students are correct in the Clearinghouse, which will be done at least 50 days out from the time students were initially reported. IT and someone in the Registrar?s office will sign off on these processes when the report is run, when the report is reviewed, and once the report is sent. The Registrar's will run the Failure Irregular Withdrawal report daily, instead of weekly to ensure all students who have not attended classes are taken out within a timely manner as soon as they are reported by the instructors. These procedures were implemented in August 2022. West Liberty University (WLU) response When the Registrar Office is recording and entering data for Withdrawal (WD) students, a review and approval process has been implemented to ensure dates and information are entered accurately and timely.

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.

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.

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.

REPORTING, AND MATCHING, LEVEL OF EFFORT, EARMARKING Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 Procedures were updated February 2023 to ensure each Employment and Training Administration report has a documented review by an appropriate individual familiar with the reporting requirements prior to submission.

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.

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.