Corrective Action Plans

For 2022, quarterly reviews were being performed; however, due to the transition in personnel in the Accounting and Finance areas, the annual review was not done. The College has updated its procedures to include a review of the annual submission similar to the current practice of reviewing the quarterly submission.

Finding 2022-002 Fed Agency Name: US Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Fund CFDA #: 21.027 Finding Summary: During the Single Audit, it was discovered the City did not have adequate internal controls over reports filed with the U.S. Department of Treasury which resulted in incorrect information being reported. Responsible Individual: Sean Richardson, CPA City Clerk/Treasurer Corrective Action Plan: Management will closely review the project and expenditure report user guide to ensure future reports are in compliance and implement controls surrounding these reports. Anticipated Completion Date: December 2022

Appropriate care will be exercised in the future to ensure that we comply with all Agency loan resolution terms.

2022-003 Moving to Work Demonstration Program (HCVP Only) ? Federal Assistance Listing Number 14.881 Recommendation: The finding recommends BRHP review their process for tracking and scheduling inspections to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to the finding: The two files reviewed with missed inspections have been scheduled for the biennial inspection and have passed inspection. BRHP has added two elements to the process for scheduling biennial inspections; including a check for excluded units prior to upload of inspections needing scheduling, as well as a validation report of scheduled inspections against those requested. Additional training has been provided to key HCV staff to review audit reports and subsequent process steps. Names(s) of the contact person(s) responsible for correction action: Pete Cimbolic, Managing Director, Operations & Program Evaluation 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.

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.

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.

REPORTING Recommendation: We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Corrective Action: The Department understands the issues and is taking corrective action to improve reporting. Due to the New Mexico emergent events that took place in FY22, the Department made the emergent events the Department?s priority and onboarding became a secondary focus for the Department. In FY23, the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2023 Responsible Person(s): Chief Financial Officer

CASH MANAGEMENT Recommendation: We realize the Department continues to have staff turnover. We recommend the Department review its process and implement effective policies, procedures, and controls to ensure the accounting records appropriately reflect the activity of the grant. The Department should consider efficiencies to make the process less cumbersome. While the Department has existing processes at the federal program level, there appears to be a need for higher level monitoring and reconciliation of federal program activity to ensure the completeness of federal program-level reconciliations and reimbursements. The Department should consider further contracting with an outside third party to aid in the process of performing reconciliations and billings. The deficit fund balance in the Federal Grants Fund (40280) should be reviewed and addressed. The Department should evaluate the need to obtain a deficiency appropriation or some other funding to cover this deficit. Corrective Action: The Department partially understands the issue. The Department will internally audit our expenditures to ensure that all transactions include an operating unit. The Department will also establish a checklist to include that all signatures are collected and that applicable documentation is received for reimbursement purposes. As part of our Sub Grant recipient review for Assistance Listings 97.036 and 97.067, we cannot reimburse the subrecipient until they submit applicable receipts for reimbursement and answer all requests for information as required by FEMA. Due Date of Completion: June 30, 2023 Responsible Person(s): Chief Financial Officer, Grants Unit Manager

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.

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).

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.

INTERNAL CONTROLS OVER CHILD CARE PROVIDER ELIGIBILITY FOR ARP ACT STABILIZATION FUNDS Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 The DHHR Bureau for Family Assistance, Division of Early Care and Education, has a process in place for the approval of ARP stabilization funding for childcare providers set forth in the West Virginia Child Care Stabilization Payment Policy and Procedure Manual that includes: ? Eligibility of childcare providers (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.1), ? Conditions under which childcare providers are eligible (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.2), ? Ineligible childcare providers (Chapter 2: Overview of WV Child Care Stabilization Payment Eligibility, Section 2.3) ? An application process for childcare providers to apply for ARP stabilization funding (Chapter 5: Application Process, Sections 5.0, 5.1 and 5.2). Beginning in August 2022, the Division of Early Care and Education began auditing childcare providers (in batches of 300) to ensure appropriate use of the funds by requesting invoices and statements showing how the provider has utilized the ARP funding they have been awarded. Each quarter, a new batch is being audited until all childcare providers participating in the ARP stabilization funding have been audited. The procedure manual referenced above explains that the documentation relevant to providers? applications, eligibility, and audit findings are maintained within each provider?s FACTS provider case record. The Division?s tracking of providers deemed to be ?in good standing? is maintained within a manually updated tracking form housed on the Division?s internal server. By May 1, 2023, the Division of Early Care and Education will modify the West Virginia Child Care Stabilization Policy and Procedure Manual to document workflows more clearly for the award and monitoring of stabilization grants, as well as how the Division will more effectively produce such documentation to ensure that controls are operating effectively.

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.

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.

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.