Corrective Action Plans

Finding 1176577 (2025-009)

Material Weakness 2025

NC

Corrective Action Plan: GSPAR will improve its internal controls, policies, and procedures to mandate a physical inventory annually. GSPAR will attest/certify all inventory once every two years, beginning in May 2026 to rectify the remaining audit deficiency. This ensures accurate tracking and accou...

Corrective Action Plan: GSPAR will improve its internal controls, policies, and procedures to mandate a physical inventory annually. GSPAR will attest/certify all inventory once every two years, beginning in May 2026 to rectify the remaining audit deficiency. This ensures accurate tracking and accountability of assets. In partnership with Moore & Van Allen JCSU also updated our equipment management policy, procedures and training modules to address this audit finding (updated January 15, 2026). Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176574 (2025-008)

Material Weakness 2025

Johnson C. Smith University

NC

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure tha...

Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. To this end the University enlisted the support of Moore & Van Allen and associates law firm to support in developing enhanced policies, procedures, and training modules to support an increased level of compliance support. Moore & Van Allen is a wellrespected international law firm that specializes in reporting compliance and compliance training.To address the specific audit concerns Moore & Van Allen in conjunction with the JCSU executive cabinet, Government Sponsored Programs, the President and Board of Trustees to develop these policies, supporting procedures and training modules. These policies have been approved as of the January 15, 2026 Board of Trustees meeting: Time and Effort Reporting Policy, Government- Sponsored Equipment and Property Management Policy, Post-Award Management Policy, Grant Records Management Policy and Revised Extra Compensation for Faculty and Staff Policy. The level of effort reporting process has been modified to a consistent reporting for all campus awards. Level of effort reports are done by academic term, and the reports are due within 60 days following the end of the term. The Office of Government Sponsored Programs (“GSPAR”) has implemented monitoring and tracking measures to all reports are captured and completed according to federal guidelines. A system of multiple reviews has been implemented to help in reducing errors in reporting and increase efficiency in timeliness of the reports. Additionally, GSPAR intends to work closely with the Human Resources division to ensure accurate and efficient Time and Effort reporting. To address this concern, the Payroll unit has been reorganized into the Business and Finance Office to streamline communication and time and effort report fidelity between Payroll and GSPAR. In addition, the University mandated participation in compliance training for all faculty and staff; participants are required to submit an acknowledgment that they participated in the training and are aware of the compliance requirements. The mandatory training will occur annually for the university and all new grant award recipients will receive this training as part of their grant startup process. All GSPAR employees will also participate in training related to time and effort and allowable costs compliance, annually. Specific to the TRIO programs, as the result of a re-organization in February 2025 the University created a new position: Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being. This role will oversee Time and Effort Reporting, Annual Performance Report submissions, and financial transactions, ensuring accuracy and adherence to all relevant policies, regulations, and procedures. Additionally, this position will support professional development initiatives to enhance grant management and compliance. The AVP will also support university efforts to conduct regular program reviews to ensure proper documentation supporting TRIO eligibility and adherence to program requirements. To improve program knowledge and standardize practices, TRIO personnel will continue engaging in professional development offered locally and nationally. Internally, the TRIO Leadership Team (TRIO Project Directors and SVP of Student Enrollment & Retention Management) established TRIO Professional Development Day, a two-day training designed specifically for JCSU TRIO staff. These sessions provide guidance on university policies, financial compliance, Time and Effort reporting, effective record-keeping, and data management. The event also includes a roundtable discussion to promote collaboration and shared learning across programs. In addition, the TRIO Leadership Team will continue to explore best practices from high-functioning TRIO programs. To enhance communication and strengthen internal controls, the TRIO Leadership Team implemented monthly TRIO Program meetings. These meetings, involving TRIO Project Directors and the Senior Vice President of Strategic Enrollment and Retention Management, facilitate discussions on compliance, streamline processes, and support policy development. Additionally, the TRIO Leadership Team established monthly interdepartmental meetings among TRIO programs, the Division of Government Sponsored Programs and Research, and the Division of Business and Finance to further ensure alignment with institutional and federal requirements. Human Resources will also participate in future meetings to review Time and Effort Reporting procedures. TRIO Project Directors maintain ongoing communication with the Department of Education Program Officer, seeking written guidance on allowable costs, staffing adjustments, and fund reallocations, when necessary. Continuous monitoring and evaluation will ensure the effectiveness of these corrective actions, allowing the university to identify areas for ongoing improvement and maintain full compliance with all regulatory requirements Anticipated Completion Date: December 2026

View Audit 390365

Finding 1176568 (2025-007)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: To address the deficiencies identified in Finding 2025-008, the University has implemented and continues to strengthen a Registrar-led corrective action framework focused on improving the accuracy, timeliness, and oversight of Campus-Level and Program-Level enrollment reporti...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-008, the University has implemented and continues to strengthen a Registrar-led corrective action framework focused on improving the accuracy, timeliness, and oversight of Campus-Level and Program-Level enrollment reporting to the National Student Loan Data System (NSLDS). Primary Control Enhancements. The University has engaged Strata Information Group (SIG) to support validation and configuration of enrollment reporting functionality within Ellucian Colleague. This engagement assists the Registrar’s Office in ensuring that enrollment status changes, credential completions, and program-level data are transmitted accurately through established reporting processes. Responsibility for enrollment reporting remains with the Office of the Registrar, with SIG serving in a technical advisory capacity. The Office of the Registrar will establish a structured enrollment reporting cadence, including submission of enrollment files on a bimonthly basis. This reporting schedule will ensure timely identification and reporting of enrollment status changes in compliance with federal requirements and reduce reliance on ad hoc or event-driven reporting. Supporting Controls and Training. To further strengthen upstream data integrity, the Registrar’s Office will implement enrollment governance controls, including restricting late graduation applications and limiting major declarations to designated academic periods. These controls reduce late-cycle data changes that previously contributed to reporting inconsistencies. Monitoring and Quality Assurance. The Office of the Registrar has institutionalized a formal quality assurance calendar requiring enrollment reporting reviews at least twice per semester. These reviews validate the accuracy and timeliness of Campus-Level and Program-Level enrollment data reported to the National Student Clearinghouse (NSC) and, by extension, NSLDS. As part of this monitoring framework, the Registrar’s Office will conduct periodic sampling of reported enrollment records to confirm compliance with reporting timelines and verify the effectiveness of enrollment reporting controls. Sustained Oversight. Any discrepancies identified through quality assurance reviews will be documented, corrected, and evaluated to inform process refinement and prevent recurrence. To support reconciliation and data validation, the Registrar’s Office will meet monthly with the Office of Data Analytics to compare enrollment data within Ellucian Colleague to downstream reporting outputs. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176566 (2025-006)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a sc...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-006, The Offices of Student Accounts and Financial Aid offices (“the Offices”) will improve coordination and communication regarding the timing of fund transfers and refund disbursements. The Offices have established a schedule to begin the refund process 10 calendar days of the credit balance creation date to ensure compliance with the 14-day federal requirement. A written processing calendar has been established to track key deadlines and responsibilities. These actions establish preventive controls to ensure all Title IV credit balances are refunded within the federally required timeframe and to prevent recurrence. Ongoing monitoring of this process will ensure the University issues Title IV refunds within 14 days of the credit balance being applied to the student’s account. Anticipated Completion Date: December 2026

View Audit 390365

Finding 1176563 (2025-005)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: To address the deficiencies identified in Finding 2025-005, the University has implemented and continues to strengthen a comprehensive corrective action framework focused on automating Return of Title IV (R2T4) processing, clarifying cross-functional responsibilities, enforci...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-005, the University has implemented and continues to strengthen a comprehensive corrective action framework focused on automating Return of Title IV (R2T4) processing, clarifying cross-functional responsibilities, enforcing withdrawal data integrity, and institutionalizing quality assurance and supervisory oversight. Primary Control Enhancements. Ellucian Colleague has been configured to automate R2T4 calculations and prevent post-withdrawal disbursements without documented authorization, supported by system-generated audit trails. Supporting Controls and Training. Controls governing withdrawal determination have been strengthened, including required reporting of last date of attendance as a part of grade submission and faculty training to support accurate withdrawal data. This requirement strengthens the integrity of withdrawal data, supports accurate determination of official and unofficial withdrawal dates, and ensures that R2T4 calculations are based on verified enrollment activity. The University has clarified and formalized cross-functional responsibilities related to withdrawal determination and R2T4 processing. Controls now ensure structured communication between academic units, the Office of the Registrar, and the Office of Financial Aid, with defined ownership for initiating, calculating, reviewing, and completing R2T4 determinations. Monitoring and Quality Assurance. To ensure accuracy and timeliness, the University has implemented a secondary review process for all R2T4 calculations. Initial calculations completed in Ellucian Colleague are independently validated using the Return of Title IV calculation tools within the Common Origination and Disbursement (COD) system. This secondary calculation serves as a quality control measure prior to final processing and fund return. In addition, R2T4 activity is subject to periodic quality assurance reviews, including monitoring of calculation timeliness, authorization documentation, and fund return deadlines. Sustained Oversight. Any discrepancies identified by QA reviews are documented, corrected, and reviewed to inform process improvements and staff training. Supervisory oversight is in place to ensure compliance with federal timelines and calculation requirements. Anticipated Completion Date: August 2026

View Audit 390365

Finding 1176560 (2025-004)

Material Weakness 2025

Johnson C. Smith University

NC

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

Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit t...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-004, the University has implemented and continues to enhance corrective actions focused on automating loan disbursement notifications, standardizing notification content and timing, strengthening documentation and audit trails, and institutionalizing quality assurance oversight to ensure sustained compliance with federal notification requirements. Primary Control Enhancements. Loan disbursement notifications to the student for Subsidized, Unsubsidized, and Graduate PLUS Loans are now system-generated through Ellucian Colleague, providing automated delivery and a documented audit trail. Notifications are issued upon disbursement processing and delivered through system-supported modalities, including electronic communication and student portal updates. Ellucian Colleague retains a system-generated audit trail documenting the timing and content of each notification, strengthening the University’s ability to demonstrate compliance with federal requirements. This system-based approach eliminates reliance on third-party notification tools previously used and brings direct control of notification sequencing, content, and documentation within the University’s financial aid infrastructure. Supporting Controls and Training. The University has revised the Parent PLUS Loan notification process to ensure that required disbursement information—including the date, amount, and type of loan—is provided directly within the notification communication. While Parent PLUS notifications currently require initiation through a controlled manual process, procedures have been amended to ensure timely issuance, content accuracy, and supervisory oversight during this interim period. The University is actively working with the Ellucian Colleague implementation team to further automate Parent PLUS Loan disbursement notifications and eliminate manual triggering. Until full automation is achieved, documented procedures and quality assurance reviews will serve as compensating controls to ensure compliance with notification timing and content requirements. Monitoring and Quality Assurance. The University established and maintains a formal quality assurance framework to monitor loan disbursement notifications. A quality assurance calendar requires reviews at least twice per semester to confirm that notifications are issued within required regulatory timeframes, include all required elements, and are sent to the appropriate recipient (student or parent). As part of ongoing monitoring, the University has conducted multiple quality assurance reviews of loan disbursement notifications. These reviews have demonstrated improved compliance with notification timing and content requirements while also identifying isolated system sequencing issues that were promptly addressed through configuration updates and enhanced scheduling controls within Ellucian Colleague. Sustained Oversight. Any discrepancies identified through quality assurance reviews are documented, corrected, and evaluated to inform process refinement, system configuration, and staff training. Anticipated Completion Date: September 2026

View Audit 390365

Finding 1176559 (2025-003)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior t...

Corrective Action Plan: To address the deficiency identified in Finding 2025-003, the University has implemented and is continuing to formalize corrective actions focused on strengthening award notification sequencing, automating required communications, and ensuring a verifiable audit trail prior to the disbursement of Title IV funds. Primary Control Enhancements. With the assistance of Financial Aid Services (FAS), Ellucian Colleague has been configured to automate award notification generation upon completion of student packaging, creating a system-generated audit trail that documents notification timing relative to disbursement. This automation ensures that award notifications are issued prior to disbursement activity and creates a system-generated audit trail documenting the timing and issuance of the notification. Supporting Controls and Training. Financial Aid staff receive ongoing system and compliance training to reinforce proper sequencing of notifications and disbursements. Monitoring and Quality Assurance. Routine quality assurance reviews confirm that award notifications are issued and documented prior to disbursement, with exceptions documented and corrected. Sustained Oversight. Any exceptions identified will be reviewed, documented, and corrected to ensure sustained compliance. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176555 (2025-002)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliati...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176553 (2025-001)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutional...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-001, the University has undertaken and continues to implement a comprehensive corrective action strategy focused on strengthening financial aid systems, standardizing processes, enhancing staff capacity, and institutionalizing quality assurance and oversight mechanisms. Primary Control Enhancements. The University transitioned from PowerFAIDS to Ellucian Colleague as the system of record for financial aid awarding, enabling automated enforcement of packaging, eligibility, and fund-specific awarding rules. System configuration enhancements now support accurate cost of attendance calculations, enforcement of loan limits, and eligibility sequencing based on updated ISIR data, reducing reliance on manual intervention. Supporting Controls and Training. To support the implementation and stabilization of these controls, the University partnered with Financial Aid Services (FAS) in February 2025 to conduct a comprehensive review of financial aid systems, processes, and internal controls. Through this partnership, FAS has provided experienced Colleague specialists to support annual system setup, troubleshooting, validation of awarding rules, and targeted staff training. In addition, Financial Aid staff participate in ongoing professional development through the National Association of Student Financial Aid Administrators (NASFAA) and Federal Student Aid (FSA) to ensure continued proficiency and regulatory awareness. Monitoring and Quality Assurance. A formal quality assurance framework has been institutionalized, requiring eligibility and award accuracy reviews at least twice per semester. Reviews validate FSEOG prioritization by Student Aid Index (SAI), resolution of ISIR comment codes prior to disbursement, compliance with annual and lifetime loan limits, and alignment between cost-of-attendance values maintained in Ellucian Colleague and those reported to COD. Since the implementation of enhanced system controls and QA procedures, the University has conducted multiple eligibility and award accuracy reviews across Title IV programs, including Direct Loans, Pell Grants, and cost-ofattendance reconciliation. These reviews have demonstrated improved accuracy and control effectiveness, while also identifying isolated issues that were addressed through system updates or corrective adjustments. Sustained Oversight. Results of quality assurance reviews are documented, corrected, and analyzed to inform system configuration, staff training, and supervisory oversight. These controls ensure that improvements supported through the FAS partnership are institutionalized within university operations and sustained beyond the initial remediation period. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176549 (2025-005)

Material Weakness 2025

Bettendorf Community School District

IA

School Nutrition Programs

Response and Corrective Action Plan: The District will implement a process to review and retain records used in determining eligibility as outlined by the Iowa Department of Education and Office of Management and Budget.

View Audit 390321

Finding 1176542 (2025-004)

Material Weakness 2025

State of West Virginia

WV

Cash Management Reporting Student Financial Aid § 200.303

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, W...

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, WVSTO staff experienced multiple extenuating circumstances including training of newer staff members, medical treatments, illness, and the sudden unexpected passing of a close family member. Realizing that these circumstances would interfere with the timely submission of the Annual Report, an extension was requested on December 30, 2025, with the Bureau of the Fiscal Service and was granted through Friday, January 9, 2026. Regrettably, the extenuating circumstances were not fully resolved by that date, and the report was ultimately submitted on January 14, 2026. The WVSTO remained focused on completing the Report but overlooked the need to request an additional extension. WVSTO staff subsequently met with Angela Smith, Director of the Bureau of the Fiscal Service and staff members Mary Bailey and Christopher Bush from the Revenue Collections Management Team. Director Smith confirmed there will be no penalties assessed due to the late filing. Additionally, WVSTO Banking Services staff will review the internal timeline of CMIA activities and procedures to ensure that future reporting is complete and submitted in a timely manner.

View Audit 390319

Finding 1176540 (2025-018)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.320 § 200.334 § 200.520

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the ...

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the three allowable criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. A Self-Certification letter will be developed and maintained by April 30, 2026, while formally defining micro-purchase thresholds applied to federal awards. This selfcertification letter will be retained as part of our procurement documentation and will provide how the micro-purchase threshold was determined and applied in accordance with 2 CFR §200.320(a)(1)(iv). Bluefield State University (BSU) response: Beginning in FY 2026, the BSU Controller and Director of Purchasing will review the criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. These requirements will be presented to the Board of Governors before June 30, 2026.

View Audit 390319

Finding 1176536 (2025-017)

Material Weakness 2025

State of West Virginia

WV

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

2025-017 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.659 DOHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $26 was unavailable at the time of the audit, these transac...

2025-017 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.659 DOHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $26 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

View Audit 390319

Finding 1176534 (2025-016)

Material Weakness 2025

State of West Virginia

WV

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

2025-016 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $50 was unavailable at the time of the audit, th...

2025-016 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $50 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

View Audit 390319

Finding 1176533 (2025-015)

Material Weakness 2025

State of West Virginia

WV

Allowable Costs / Cost Principles Eligibility § 200.303 § 200.403

2025-015 ALLOWABLE COSTS/COST PRINCIPLES, ELIGIBILITY DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS’s corrective action plan from the prior audit indicated that a system change was made during FY 2025 to prevent future payments to psychiatric facilities from b...

2025-015 ALLOWABLE COSTS/COST PRINCIPLES, ELIGIBILITY DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS’s corrective action plan from the prior audit indicated that a system change was made during FY 2025 to prevent future payments to psychiatric facilities from being charged to the Foster Care program. This change did go into effect on September 19, 2024. However, this provider was an anomaly. The facility was a Residential Treatment Facility which was Title IV-E eligible until they received Psychiatric Residential Treatment Facility (PRTF) status in August of 2024, however, they did not provide DOHHS documentation until February 2025. Immediate action was taken by a call ticket to the Technical Call Center to ensure that the PRTF was not continuing to show as IV-E eligible. The staff from the Division of Regulatory Management will continue, as part of their annual licensing review will ensure wvPATH provider records are updated to reflect timely licensing status as well as ensuring that child specific agreements do not lapse. The previously stated Corrective Action Plan remains in place and will continue.

View Audit 390319

Finding 1176531 (2025-014)

Material Weakness 2025

State of West Virginia

WV

Special Tests & Provisions Subrecipient Monitoring Eligibility

2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to m...

2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to maintain continual monitoring of conducted Annual Unannounced Monitoring Visits required under 45 CFR §98.42(b)(2)(i)(B). Within the tracking spreadsheet, detailed information is input from our documentation system PATH COGNOS Report PCC-PLI 1080. Information includes Provider Name, Provider Number, Provider Type, Specialist Name, and columns for visits conducted and visits not yet conducted. To provide an overall year-to-date calculation of monthly totals/percentages, a Yearly Summary tab is included in the spreadsheet for a quick reference analysis to provide an additional method of tracking visits. As the monthly totals and percentages change, the data updates on the monthly tabs and the Yearly Summary tab. Program Managers have implemented individual efforts to track visits conducted by specialists. The PCC-PLI 1080 report is distributed twice per month by PM II to each Program Manager for review. Specialists have been instructed to include completed annual unannounced monitoring visits on monthly report data, which can then be compared with the PCC-PLI-1080 reports. Additionally, a tracking system has been implemented that requires specialists to pre-plan annual unannounced visits for the 2026 calendar year to ensure visits are completed.

View Audit 390319

Finding 1176528 (2025-013)

Material Weakness 2025

State of West Virginia

WV

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2025-013 West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on...

2025-013 West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on the spreadsheet. The reminder function will be used to ensure this step is not missed in the future. WVSOM registrar will check the report diligently for accuracy. Southern West Virginia Community and Technical College (SWVCTC) response: SWVCTC is consulting with the Clearinghouse to better understand and identify any data elements of concern. SWVCTC is working to resubmit enrollment files and will review each file to ensure the data and processes are correct. An internal review by the CIO and Registrar will be done on each submission for a period of at least six months or until all parties are satisfied with the submissions. REPORTING – SPECIAL REPORTING – LIHEAP CARRYOVER AND REALLOTMENT REPORT DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.568 To strengthen internal controls, the Office of Grants Management will reevaluate its current process for tracking LIHEAP program reporting requirements and meeting deadlines. This evaluation, which will be completed by July 1, 2026, will aim to identify specific staff training needs.

View Audit 390319

Finding 1176526 (2025-022)

Material Weakness 2025

State of West Virginia

WV

Eligibility Special Tests & Provisions Material Weakness § 200.303

2025-022 SPECIAL TESTS AND PROVISIONS – INCOME ELIGIBILITY AND VERIFICATION SYSTEM DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.558 Effective April 1, 2026, the Department of Human Services’ Bureau for Family Assistance will implement a series of mandatory training and policy en...

2025-022 SPECIAL TESTS AND PROVISIONS – INCOME ELIGIBILITY AND VERIFICATION SYSTEM DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.558 Effective April 1, 2026, the Department of Human Services’ Bureau for Family Assistance will implement a series of mandatory training and policy enhancements designed to bolster compliance and documentation standards for all WV WORKS workers. The primary focus of these updates is the rigorous handling of data matches; specifically, workers must complete a Blackboard course on Single Agency Audits that emphasizes the necessity of documenting all Income and Eligibility Verification System (IEVS) matches. To support this at the foundational level, an IEVS case comments exercise has been integrated into the third week of the standard training curriculum. Monitoring and quality control will also enhance Rushmore Review protocols. Supervisors are now required to perform three Rushmore Reviews per month, while the WV WORKS policy team will continue their own reviews to track systemic trends. Furthermore, the Division of Performance and Quality Improvement (DPQI) will now include specific compliance checks for data match completion within their monthly review of 18 cases. To ensure staff are well-equipped for these changes, the Division of Professional Development has released a suite of resources, including procedural Desk Guides and supplementary YouTube training videos. Supervisors are required to present them during monthly unit meetings. To finalize the process, every worker must provide a formal sign-off to confirm they have received and understood the updated procedures regarding data exchanges. 85

View Audit 390319

Finding 1176523 (2025-021)

Material Weakness 2025

State of West Virginia

WV

Subrecipient Monitoring § 200.303 § 200.332

2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication ...

2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication kept within subaward files. For future subawards, the Department of Agriculture will create a checklist based on 2 CFR 200.332 (b)(1) to use in review of new agreements (one checklist per funding source), including section citations for the required elements.

View Audit 390319

Finding 1176522 (2025-020)

Material Weakness 2025

State of West Virginia

WV

Equipment & Real Property Management § 200.303 § 200.313

2025-020 EQUIPMENT AND REAL PROPERTY MANAGEMENT DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 The property for which adequate records (tested against 2 CFR 200) were unavailable for the Department of Agriculture was purchased in 2010, before the implementation and 2 CFR 200. Fede...

2025-020 EQUIPMENT AND REAL PROPERTY MANAGEMENT DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 The property for which adequate records (tested against 2 CFR 200) were unavailable for the Department of Agriculture was purchased in 2010, before the implementation and 2 CFR 200. Federal financial assistance for State governments was governed by circular A-102 during time of purchase which did not have equivalent property management requirements as found in circular A-110 and subsequently 2 CFR 200. Adequate records were available for the two additional properties sampled purchased in 2017 and 2021, demonstrating the current property management system and processes are adequate to meet requirements of current federal financial assistance. Moving forward, DOA will be reviewing current property records to ensure compliance with 2 CFR 200.313.

View Audit 390319

Finding 1176515 (2025-011)

Material Weakness 2025

State of West Virginia

WV

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cyber...

2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cybersecurity policy. However, due to the recently fluctuating landscape of cybersecurity, security needs involved, and the number of staff available for the task, WVSU has not yet completed, nor approved any policy beyond the preliminary stages. WVSU is committed to having a written cyber security policy by the end of 2025-2026 which will have been approved by WVSU administration. Further delaying the process was a change in CFO during FY 2026.

View Audit 390319

Finding 1176514 (2025-012)

Material Weakness 2025

State of West Virginia

WV

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

2025-012 SPECIAL TESTS AND PROVISIONS: NSLDS REPORTING WEST VIRGINIA UNIVERSITY (WVU), WEST VIRGINIA SCHOOL OF OSTEOPATHIC MEDICINE (WVSOM), SOUTHERN WEST VIRGINIA COMMUNITY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 West Virginia University (WVU) response: The Office o...

2025-012 SPECIAL TESTS AND PROVISIONS: NSLDS REPORTING WEST VIRGINIA UNIVERSITY (WVU), WEST VIRGINIA SCHOOL OF OSTEOPATHIC MEDICINE (WVSOM), SOUTHERN WEST VIRGINIA COMMUNITY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 West Virginia University (WVU) response: The Office of the University Registrar (OUR) will create an “enrollment effective date validation” step in our comparison process. OUR will take the NSC submission file generated by WVU Information Technology Services (ITS) and compare the program effective date and campus enrollment effective date for each student to ensure the dates match. Any dates that do not match will be documented or corrected. West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on the spreadsheet. The reminder function will be used to ensure this step is not missed in the future. WVSOM registrar will check the report diligently for accuracy. Southern West Virginia Community and Technical College (SWVCTC) response: SWVCTC is consulting with the Clearinghouse to better understand and identify any data elements of concern. SWVCTC is working to resubmit enrollment files and will review each file to ensure the data and processes are correct. An internal review by the CIO and Registrar will be done on each submission for a period of at least six months or until all parties are satisfied with the submissions.

View Audit 390319

Finding 1176512 (2025-010)

Material Weakness 2025

State of West Virginia

WV

Matching / Level of Effort / Earmarking Student Financial Aid Cash Management § 200.303

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunctio...

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunction with the GSU Business and Finance Office, has implemented policies and procedures to perform, at a minimum, monthly Pell Grant and Direct Loan reconciliations, with the appropriate signoffs. The GSU Financial Aid Office reviews and reconciles all Pell Grant and Direct Loan disbursement records at least monthly by comparing Banner records to Common Origination and Disbursement (COD) records. If any do not match, the GSU Financial Aid Office notes this within their documentation and resolves these discrepancies in a timely manner. They are reconciled by the GSU Financial Aid Office, signed off by the reconciling staff member, as well as the Financial Aid Director. Further, the GSU Business and Finance Office Accountant and GSU Financial Controller review and sign-off the reconciled data. The final copy is kept within the GSU Financial Aid Office. 78 Southern West Virginia Community and Technical College (SWVCTC) Response: A Monthly Reconciliation Cover Sheet has been developed. The Financial Aid Counselor will complete the monthly and annual reconciliation for each fund (e.g., Pell Grant, Student Loans). The cover sheet will document the month reconciled, the fund being reconciled, the amount disbursed in Banner, the amount disbursed through COD, any discrepancies with explanations, and the preparer’s signature. The applicable SAS Reconciliation for each fund will be attached to the cover sheet. Upon completion, the reconciliation and cover sheet will be reviewed and approved by the Director of Student Financial Assistance.

View Audit 390319

Finding 1176502 (2025-019)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.214 § 200.303

2025-019 SUSPENSION AND DEBARMENT HIGHER EDUCATION POLICY COMMISSION Assistance Listing Number: 47.076 This finding was previously identified during the FY 2024 audit. Since the original finding, HEPC has addressed and resolved this issue by strengthening its internal controls and procedures. On Mar...

2025-019 SUSPENSION AND DEBARMENT HIGHER EDUCATION POLICY COMMISSION Assistance Listing Number: 47.076 This finding was previously identified during the FY 2024 audit. Since the original finding, HEPC has addressed and resolved this issue by strengthening its internal controls and procedures. On March 31, 2025, HEPC updated policies and procedures that established and maintain effective control over federal awards. The update established a threshold for identifying covered transactions and provides clear guidance on conducting suspension and debarment searches in SAM.gov for those transactions. The update also provided additional steps for documentation required to assess whether a vendor is excluded or disqualified if not in SAM.gov. The instances noted in this finding happened before the corrective action plan was implemented. Management believes the updated processes and procedures are effective.

View Audit 390319

Finding 1176499 (2025-009)

Material Weakness 2025

State of West Virginia

WV

Matching / Level of Effort / Earmarking Subrecipient Monitoring Reporting § 200.303

2025-009 REPORTING SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS OFFICE OF THE GOVERNOR (GO) Assistance Listing Number: 21.027 The GO fully believes that its documentation and support for obligations and expenditures incurred under its SLFRF funding is available and appro...

2025-009 REPORTING SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS OFFICE OF THE GOVERNOR (GO) Assistance Listing Number: 21.027 The GO fully believes that its documentation and support for obligations and expenditures incurred under its SLFRF funding is available and appropriate to support all items, though recognizes there were challenges and delays in its ability to provide the information to our auditors due to miscommunications and need to coordinate across multiple agencies. That said, the GO recognizes that certain errors were noted in the amounts reported in the quarterly expenditure reports and is committed to enhancing its processes going forward. In particular, as the new administration has had a chance to become more familiar with the reporting processes and its relationship with the third-party firm responsible for assisting the State’s creation and submission of its expenditure reporting. In particular, the GO will ensure that each quarterly expenditure report includes a clearly defined project schedule that allows ample time for the full review and confirmation of information and data included prior to the report’s due date. Additionally, the third-party firm has added additional resources to support the reporting periods and developed new templates to better track and summarize the information aggregated across all agencies spending SLFRF funds to better enable review and identification of any errors or questions.

View Audit 390319

Corrective Action Plans

Filters