Corrective Action Plans

The College reported the students? status to the National Student Clearinghouse (NSC). The NSC in turn is contractually engaged by the College to update NSDLS. We will work with NSC to determine why the students? status was not updated timely and ensure that student status is accurately and timely reported to NSLDS going forward.

Condition: The Health Center?s Period 2 report to HHS included duplicate amounts for utilities expenses. Planned Corrective Action: Management will continue to refine processes to more diligently review expenses to ensure no duplicate expenses are included in the underlying supporting documentation. However, the Health Center included as eligible expenses in the Period 2 submission only those amounts up to the funding received, plus accrued interest. Had the noted questioned costs been identified prior to submission, the Health Center would have included additional amounts in the eligible expenses reported in the PRF reporting portal to demonstrate satisfactory use of the PRF funding received. The Health Center had $418,778 in additional eligible operating expenses which were not included in the Period 1 submission and $1,916,769 in additional eligible capital expenses not included in the Period 2 submission which would have been used to replace the identified questioned costs. Person Responsible: Wade Eschenbrenner, CFO Anticipated Completion Date: Ongoing

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

SUBRECIPIENT MONITORING Division of Emergency Management (DEM) Assistance Listing Number 97.036, COVID-19 97.036 A new grant monitor has been hired for the recovery grants managed by DEM. The monitor has reviewed and updated the agency policies related to subrecipient monitoring and is conducting training with other program staff to ensure understanding. The Public Assistance (PA) Program in DEM has completed the Risk Assessment for 2022 using the risk assessment tool and identified the highest risk project worksheets. DEM is reviewing the municipal audits conducted by the State Auditor?s office for PA sub-recipients. DEM has developed a Monitoring Plan for the coming year and completed a calendar of upcoming monitoring visits. DEM is using the FEMA approved monitoring protocol and the subrecipient monitoring standards outlined in 2 CFR 200.303, and it is our belief that we are complying with all applicable regulations and requirements.

REPORTING Division of Emergency Management (DEM) Assistance Listing Number 97.036, COVID-19 97.036 To resolve the finding and refine our processes through our new understanding of the requirements, DEM will re-evaluate all Federal Funding Accountability and Transparency Act (FFATA) reports that have already been submitted in the FFATA Subaward Reporting System (FSRS) this year for accuracy and adherence to the requirements. Upon review, any needed corrections will be made, and the reports will be re-submitted. Further, DEM met with Public Assistance and other grant program leads to relay the newly understood expectations and to review the finding for further input and resolution. DEM will implement a procedural checkpoint between program staff and internal auditing staff to ensure that the information submitted is correct and complete. All FFATA reporting will continue to be based upon obligations and not payments, original subaward obligations will be reported within 45 days of obligation, any additional subaward obligation amendment will be reported within 45 days of obligation, all subawards reported will include a project description, and all submitted reports will have a review requiring the signature of the person submitting the report as well as one additional staff member that audits the report against the available information. These updates are expected to be completed and implemented by May 2023.

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.

SCHEDULE OF EXPEDNITURES OF FEDERAL AWARDS Division of Corrections and Rehabilitation (DCR) Assistance Listing Number 93.788 The Division of Administrative Services provides fiscal oversight for the DCR. While reporting for the Opioid STR grant, the expenditures were calculated incorrectly and included transactions outside of the current fiscal year. Policies and procedures have been updated effective January 2023 to ensure the SEFA is reported accurately using the correct parameters on the reports.

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.

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The DHHR Bureau for Behavioral Health concurs with the recommendation to mandate additional documentation to support amounts of drawdowns that appear to exceed a subrecipient's immediate cash needs. Upon identification of the condition that led to this finding, the bureau provided additional guidance to all internal grant staff. The guidance was distributed on October 25, 2022 and requires a documented justification for approval of any invoice that appears to exceed 10% of total grant amount for cash on hand. The bureau also intends to seek out and provide technical assistance and/or training for internal staff and subrecipients to ensure they understand the cash management requirements within 2 CFR 200.305.

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.

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.

TRANSPARENCY ACT REPORTING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, COVID-19 93.558, 93.568, COVID-19 93.568 The Office of Grants Management, Division of Grant Administration and Reporting, is responsible for submitting the FFATA reports for the DHHR. The FFATA reports are available for all newly issued subawards and change orders throughout the DHHR each month. The source for these FFATA reports is the DHHR's subrecipient Grants Management Solution system (CRM) and an interface with the state accounting system (wvOASIS). Grants Management reviews each federal Notice of Grant Award to determine if reporting is required. Notes are input on the FFATA reports for each subaward as to whether that subaward is being reported or not. Grants Management then uploads and reviews the required data elements onto FSRS.gov before the reports are electronically submitted. For prior DHHR grant awards (e.g., fiscal year 2021), even if the DHHR passed through a portion of the award to other components of the State of West Virginia (i.e., other non-federal entities that are governmental agencies of the state but are external to the DHHR), the DHHR considered those other governmental agencies to be subrecipients of the DHHR instead of being part of the state's prime recipient tier. This viewpoint proved to be incorrect because transfers of federal awards to another component of the same auditee under 2 CFR 200, Subpart F, do not constitute a subrecipient or contractor relationship; furthermore, a grant agreement is the only means by which the DHHR can pass through a portion of the federal award to state agencies that are external to the DHHR. During fiscal year 2022, the DHHR revised its practice when awarding funds to agencies of the state that are external to the DHHR. The DHHR began considering those other governmental agencies to be part of the state?s prime recipient tier instead of being first tier subrecipients of the DHHR. Accordingly, when transferring federal awards to another state agency, the DHHR Office of Grants Management and DHHR Spending Units started working together as necessary to ensure that all subawardee information for the state is complete and accurate. During fiscal year 2022, the DHHR also revisited its standard grant agreement template in relation to other state agencies. Although changes to the main body of the grant agreement were not necessary, the DHHR made a revision to Exhibit G (?Required Reports?) of the agreement. When a ?grant? was provided to another state agency using federal funds as the source of the grant, in whole or in part, the Office of Grants Management instructed the spending unit to review the detailed line-item budget and conduct other pre-award procedures as may be necessary (e.g., inquiring of the other state agency) to determine if the other state agency planned to subgrant a portion of the funds. If the other state agency planned to subgrant a portion of the funds, the Office of Grants Management required the spending unit to include a clause within Exhibit G of the grant agreement that required the other state agency to provide the FFATA data to the spending unit on a monthly basis (due 15 days after the end of each month). Upon receiving the FFATA data from the other state agency, the spending unit was then required to submit the information to the DHHR Office of Grants Management for purposes of timely FFATA reporting to FSRS.gov. Prior to October 5, 2022, this process was accomplished via informal discussions (e.g., emails to and from other state agencies, monitoring calls, meetings held between the Office of Grants Management and spending units on a regular basis, etc.). Effective October 5, 2022, the DHHR formalized this process via a system directive from DHHR Finance to all users of the DHHR's subrecipient Grants Management Solution system (CRM). These additional controls should resolve the condition that led to the LIHEAP portion of the finding. For the TANF portion, the Context section of the finding references subawards from the West Virginia Department of Education (DOE). As additional context, when issuing their subawards, it should be noted that the DOE utilized TANF monies that it had received from the DHHR. When passing through the money to the DOE, the DHHR utilized a grant agreement since such an agreement is the only means by which the DHHR could pass through a portion of the award to another state agency. During fieldwork for the West Virginia Single Audit, the DOE informed the State?s independent auditors that the DOE subgranted a portion of the TANF funds to five different subrecipients; the State?s independent auditors then informed the DHHR. This was unbeknownst to the DHHR at the time. From a general regulatory perspective, the DHHR grant agreement required the DOE to obtain prior written approval from the DHHR before entering into any subgrant agreements with the funds. From a budgetary perspective, the DOE was required to contact the DHHR spending unit for prior approval and specific instructions regarding the subgranting of DHHR awards; provide the names of each organization that would receive subgrants, when known; and provide an overall narrative stating the purpose of each subgrant. From the FFATA perspective, the DHHR spending unit was required to utilize the DOE?s budgetary narrative, add a related reporting requirement within Exhibit G of the grant agreement, and utilize the resulting disclosures when submitting data to the DHHR Office of Grants Management for purposes of accurate FFATA reporting to FSRS.gov. The breakdown in controls happened because the DOE did not obtain prior written approval from the DHHR spending unit prior to entering into the subgrant agreements and did not indicate any subgrant expenditures within their quarterly financial reports and reconciliations of payments received and actual expenditures incurred, all of which are required per the terms and conditions of the DHHR grant. To enhance the controls, the DHHR spending unit will increase the level of risk associated with the DOE and will impose additional award conditions upon the DOE, such as requiring the DOE to submit certifications or written representations regarding subawards in the future, as are authorized per 2 CFR 200.209 (?Certifications and representations?).

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.

INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788, 93.575, COVID-19 93.575, 93.596, 93.558, COVID-19 93.558, 93.323, COVID-19 93.323 In an effort to enhance the manner by which it documents the assessment of risk, DHHR Finance has developed a Risk Assessment Form and Certification for the Award and Monitoring of Grants. Prior to submitting a draft grant agreement to DHHR Finance for processing, the spending unit will be required to complete the risk assessment form, affix any supporting documentation if desired or deemed necessary for proper disclosure, and upload a copy of the package to the Document Manager section of DHHR's subrecipient Grants Management Solution system (CRM). As part of their review of the draft grant agreement, the Office of Grants Management will check the Document Manager section of CRM to ensure the form is uploaded, completed in full, and signed by the Spending Unit. If the form is not in the Document Manager section of CRM or is incomplete, the Office of Grants Management will return the grant agreement to the Spending Unit via the standard workflow process. To ensure these additional controls surrounding Grantee evaluations and monitoring are working as intended, the Office of Internal Control and Policy Development will select a sample of forms to review on an intermittent basis; discuss the forms, the process for completing the forms, and the backup documentation with the Spending Unit if deemed necessary; and report the results to the DHHR Chief Financial Officer for further action or instructions. The risk assessment form and process are currently in draft form and under internal review. If approved, the form and process will be effective for all grant awards with a start date beginning on or after July 1, 2023. To enhance the manner by which the DHHR documents the level of monitoring during various stages of the grant, the DHHR still plans to break out the mandatory monitoring checklist (i.e., the certifications required within the checklist) into multiple parts, which will include documenting subrecipient risk and the monitoring activities that are performed throughout the life cycle of the grant. Although the formal corrective action plan in the prior year indicated that the estimated date for completion was September 30, 2022, the estimated date for completion at this stage is July 1, 2023.

CASH MANAGEMENT Southern West Virginia Community and Technical College, West Virginia Northern Community and Technical College, and Mountwest Community and Technical College Assistance Listing Number 84.425E, 84.425F, 84.425J, 84.425M Southern West Virginia Community and Technical College (SWVCC) response SWVCC has implemented new procedures for drawdowns of federal funds. Federal grants are done on a reimbursement basis. Due to the unpredictability of when invoices may be processed at the State level, SWVCC will ?front? the expenses from State funds moving forward. Separate accounts have been set up in our accounting system for this purpose. Once invoices have been paid and posted to the wvOasis accounting system, SWVCC will run periodic reports to request reimbursement of grant eligible expenses. Documentation will be completed demonstrating the exact expenses (transactions) being requested for reimbursement and the expenses will be reviewed before a drawdown is approved. This documentation will be maintained for audit review. These procedures are in place as of January 2023. West Virginia Northern Community and Technical College (WVNCC) response WVNCC has added a layer of control by transferring the task of federal fund drawdowns from the Comptroller to the Accountant Senior to the Comptroller and CFO. In addition, WVNCC has transferred the task of reconciling federal funds from the Accountant Senior to the Comptroller. This action was implemented in January 2023. Mountwest Community and Technical College (MCTC) response Effective February 2022, policies and procedures were implemented to ensure drawdown requests were made through the issuance of G5 drawdown forms. For the one instance where approval signature occurred after the draw of funds, approval was obtained via email. Policies and procedures were enhanced to ensure approvals occur before drawdown from the CFO for transactions and are documented.

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.