Corrective Action Plans

Finding 46231 (2022-014)

Significant Deficiency 2022

WV

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

FINANCIAL REPORTING Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response PCTC?s Assistant Director of Fina...

FINANCIAL REPORTING Pierpont Community and Technical College and West Virginia State University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 84.408, 93.264, 93.342, 93.364, 93.925 Pierpont Community and Technical College (PCTC) response PCTC?s Assistant Director of Financial Aid (Asst.) will take screen captures of both Banner and the Common Origination and Disbursement (COD) for a monthly reconciliation of the Federal Pell Grant program. Screen captures will be printed, and comparisons will be made by the Asst. All necessary adjustments will be performed to student accounts by the Asst. or Director of Financial Aid (Director) until balanced. The Asst. will sign as an approval on reconciliation documentation and provide to the Director for review and approval. The completed monthly reconciliation information will be retained in the completed reconciliation information file on the shared drive. This process has been implemented as of July 1, 2022. The updated procedure will ensure timely processing of all federal Pell grants to students and updates in the COD system. West Virginia State University (WVSU) response Effective January 2022, WVSU reports information to COD daily. Originations and fund adjustments are imported and exported Monday through Friday for students who meet eligibility requirements by the Financial Aid Technician and the import reports are reviewed by both the Technician and a FA Administrator with corrections being made to any errors and/or rejections. The disbursement process of applying aid to student's accounts occurs weekly throughout the semester after enrollment hours have been confirmed. The disbursement process in Ellucian Banner is completed by the Financial Aid Technician and funds are applied to student's accounts. The Director of Financial Aid proceeds to review the disbursement roster to confirm accuracy of fund sources, fund amounts and enrollment hours after the disbursement process has finished. The Financial Aid Technician sends the disbursement files to COD after the disbursement roster has been reviewed, and loads the response files the following morning. The load response files are reviewed by the Associate Director of Financial Aid and Director of Financial Aid to confirm acceptance. Both the Director of Financial Aid and Business and Operations Manager will sign off weekly confirming accuracy. Policies and procedures were updated August 2022 so that any corrections applied will be documented, dated and saved by the Associate Director of Financial Aid and/or Director of Financial Aid.

View Audit 40967

Finding 46230 (2022-013)

Significant Deficiency 2022

State of West Virginia

WV

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

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

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

View Audit 40967

Finding 46229 (2022-012)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING Fairmont State University, Blue Ridge Community and Technical College, Pierpont Community and Technical College, West Virginia State University, and Marshall University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.26...

SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING Fairmont State University, Blue Ridge Community and Technical College, Pierpont Community and Technical College, West Virginia State University, and Marshall University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364, 93.925 Fairmont State University (FSU) response The Appeals committee has updated policies and procedures to include the Business Analyst and the Registrar on the email communication list when a retroactive drop that changes enrollment status and/or a retroactive withdrawal is approved. FSU will identify the steps necessary at the National Student Clearinghouse to update the student?s status because this status update will be after the term has ended. FSU has put this plan into action already and will begin cleaning up retroactive drops and withdrawals from here on out. Blue Ridge Community and Technical College (BRCTC) response BRCTC provided training in October 2022 to appropriate staff members on the proper maintenance of record retention. Pierpont Community and Technical College (PCTC) response PCTC?s procedures to Title IV refunds were updated in January 2023 to enhance communication between the Financial Aid and Finance offices to ensure Finance has a copy of the student letter and additional Finance Office staff now have access to the Return to Title IV (R2T4) tracking sheet. The R2T4 tracking sheet is monitored by both the Financial Aid and Finance staff to ensure all refunds are returned within the required 45-day time period. The Director or Assistant Director of Financial Aid also review the return of aid calculations to ensure accuracy. West Virginia State University (WVSU) response Effective January 2022, WVSU utilizes the National, Student Clearinghouse (NSC) to update student?s enrollment and its effects on student?s direct loan and Pell statuses. Thorough edit checks of student data for each semester will be produced by IT on a regular basis. The Office of the Registrar, in coordination with Admissions, Dual Enrollment, and other contributors of student data, will make sure these errors are corrected. Special focus will be placed on resolving these errors before each enrollment file is produced. (Initial Data Integrity, First Check). On or around the 25th of each month, IT will produce the NSC enrollment file. Each time the file is produced, the file will be sent to the Registrar for review to ensure accuracy of the data being pulled from Banner. Registrar sends approval for upload to NSC. (Process Integrity, Second Check) The file will be uploaded to the NSC by IT, ensuring NSC received the appropriate number of records. The data will then be reviewed and any discrepancies in the data, when compared with past data, will be resolved in a timely manner. The Registrar, as the ultimate steward of student enrollment data, has taken full responsibility for resolving NSC errors. The NSC process makes sure these errors are resolved before the data is reported to the NSLDS, it is the responsibility of the Registrar to make sure these are resolved with accurate data. (Data Integrity, Third Check) After resolution of errors, the NSC will perform a final review of data before sending to the National Student Loan Data System (NSLDS). This will be reported on the NSLDS Reporting tab of the Enrollment Reporting screen in the NSC website. If data is satisfactory, the submission will be marked with "Congrats. No Errors!" by the originator "CH" (Clearinghouse). The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fourth Check) The enrollment data is then submitted to the NSLDS. After NSLDS reviews the data, any errors will be reported back through the NSC in the same manner as NSC errors. Resolution of these errors is of special importance and will be given top priority. The NSC sends emails whenever these items are updated. It is the responsibility of the Registrar to review and resolve any errors in a timely manner. (Data Integrity, Fifth Check) Marshall University (MU) response As approved by Faculty Senate and the President, the 2023 academic calendar has been adjusted so that MU?s summer semester is now one long term with parts of term within it. This calendar revision more closely resembles the current fall and spring semesters. Now that summer is one term with parts of term within, this will allow MU to report enrollment to the National Student Clearinghouse on a multiple report date submission schedule throughout the summer term.

View Audit 40967

Finding 46228 (2022-011)

Material Weakness 2022

State of West Virginia

WV

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

SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS West Virginia State University, Pierpont Community College, Bluefield State University, New River Community and Technical College, and West Liberty University Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93....

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

View Audit 40967 Questioned Costs: $1

Finding 46227 (2022-010)

Significant Deficiency 2022

State of West Virginia

WV

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

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

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

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Finding 46226 (2022-009)

Material Weakness 2022

State of West Virginia

WV

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

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

View Audit 40967 Questioned Costs: $1

Finding 46225 (2022-008)

Material Weakness 2022

State of West Virginia

WV

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

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

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

View Audit 40967

Finding 46224 (2022-007)

Material Weakness 2022

State of West Virginia

WV

Matching / Level of Effort / Earmarking § 200.303

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

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

View Audit 40967

Finding 46223 (2022-006)

Significant Deficiency 2022

State of West Virginia

WV

Reporting § 200.303 § 200.508

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (SEFA) Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 Fiscal and Administrative Management had a meeting in January 2023 to discuss SEFA preparation processes to ensure all resources needed for accurate SEFA reporting are a...

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (SEFA) Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 Fiscal and Administrative Management had a meeting in January 2023 to discuss SEFA preparation processes to ensure all resources needed for accurate SEFA reporting are available.

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Finding 46221 (2022-005)

Material Weakness 2022

State of West Virginia

WV

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

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

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

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Finding 46216 (2022-004)

Material Weakness 2022

State of West Virginia

WV

Subrecipient Monitoring Reporting School Nutrition Programs § 200.303

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

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

View Audit 40967

Finding 46209 (2022-003)

None 2022

State of West Virginia

WV

Eligibility Internal Control / Segregation of Duties

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

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

View Audit 40967

Finding 46208 (2022-002)

None 2022

State of West Virginia

WV

Special Tests & Provisions Eligibility Reporting

SPECIAL TESTS AND PROVISIONS ? ADP SYSTEM FOR SNAP Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561 Management within the DHHR appreciates and shares the auditors? concern with SNAP program integrity as it relates to the Recipient Automated P...

SPECIAL TESTS AND PROVISIONS ? ADP SYSTEM FOR SNAP Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561 Management within the DHHR appreciates and shares the auditors? concern with SNAP program integrity as it relates to the Recipient Automated Payment Information Data (RAPIDS) ADP system. DHHR would note that 7 CFR ? 272.10 begins with, ?(1) Purpose. All State agencies are required to sufficiently automate their SNAP operations and computerize systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. Sufficient automation levels are those which result in effective programs or in cost effective reductions in errors and improvements in management efficiency, such as decreases in program administrative costs?? Within the RAPIDS ecosystem for SNAP administration, this automation includes data matching measures undertaken, in compliance with related federal rules as specified in 7 CFR ? 272.8, 7 CFR ? 272.16, etc., to automate the validation of client-provided, worker-input information while mitigating the additional administrative burden of secondary review for all worker interactions with a client?s case. Policy regarding state and federal data matching is laid out in Chapter 6 of the State?s Income Maintenance Manual (IMM), which is available at https://dhhr.wv.gov/bfa/policyplans/Documents/Binder4.pdf. The primary data exchange system detailed in IMM Chapter 6 that is applicable to SNAP is the Income and Eligibility Verification System (IEVS) required by 7 CFR ? 272.8. Systems mandated federally for inclusion in the IEVS include those operated by WorkForce WV, the Internal Revenue Service (IRS), and the U.S. Social Security Administration (SSA). A variety of other sources may also be queried for the purpose of validating client-provided information entered into RAPIDS by a worker, including Veterans Affairs (VA), Beneficiary and Earnings Data Exchange (BENDEX), Beneficiary Earnings and Exchange Record System (BEERS), National Directory of New Hires, and Prisoner Matching with the Department of Corrections as well as the Federal Data Services Hub (FSDH). IMM Chapter 6, page 2 describes the purpose of data matching through the IEVS as follows: Information obtained through IEVS is used for the following purposes: ? To verify the eligibility of the assistance group (AG) ? To verify the proper amount of benefits ? To determine if the AG received benefits that were not entitled ? To obtain information for use in criminal or civil prosecution based on receipt of benefits to which the AG was not entitled. IMM Chapter 6, pages 2-3 further detail the points at which a match with the IEVS must take place: A data exchange in the eligibility system occurs: ? When a new case is created; ? When a new person is added to a benefit; ? When a person?s demographic information is changed; and, ? On a periodic basis for all individuals in the eligibility system, depending on the type of benefit being received. Requirements for independent verification of information when automated data matches fail or report a discrepancy with client-provided, worker-input information are spelled out in IMM 6.4.4. The State believes that these automations, while perhaps not foolproof, are in keeping with both the wording and intent of 7 CFR ? 272.10, 7 CFR ? 272.8, 7 CFR ? 272.16, etc., which aim to automate processes in order to reduce administrative burden and associated costs, such as those that would be associated with a secondary review of all worker interactions with a client?s case. With that in mind, the State commits to working to bolster SNAP program integrity as it relates to the auditors? expressed concerns through completion of the USDA-FNS SNAP System Integrity Review Tool (SIRT) in alignment with USDA-FNS requirements and timelines to ensure that automated processes within RAPIDS continue to comport with federal requirements for ADP systems. The DHHR Bureau for Family Assistance, Division of Performance and Quality Improvement (DPQI), will continue its ongoing SNAP case reviews, as well as continue its efforts to report compliance with monthly requirements for expanded supervisor case reviews conducted and tracked through the Rushmore case review system, as mandated in a December 7, 2022 memorandum to supervisors. Furthermore, the Bureau for Family Assistance will develop additional worker training, to include the reinstatement of face-to-face Statewide Payment Accuracy Conferences, with an aim to ensure that client information is accurately captured in RAPIDS so the APD can perform its automated functions with integrity.

View Audit 40967

Finding 46205 (2022-044)

Significant Deficiency 2022

State of West Virginia

WV

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

INTERNAL CONTROL ? PAYROLL Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, 93.658, 10.557 For the condition whereby a timecard for the WIC program was not approved by a manager in the automated payroll system, the DHHR Office of Human Resources Management (OHRM) r...

INTERNAL CONTROL ? PAYROLL Department of Health and Human Resources (DHHR) Assistance Listing Number 93.558, 93.658, 10.557 For the condition whereby a timecard for the WIC program was not approved by a manager in the automated payroll system, the DHHR Office of Human Resources Management (OHRM) received confirmation from the manager that the timecard was accurate. However, the confirmation was not obtained until after the state?s independent auditors inquired about the timecard. To enhance the controls and improve the documentation surrounding timecard approvals in general, the OHRM has instructed their payroll processors to use a log to note any issues with timecards prior to signing off on the timecards within the automated payroll system. The log will be shared with timekeepers and managers in the field (i.e., the various DHHR bureaus and offices throughout the state). The timekeepers and managers in the field will be required to note resolution of the issues directly on the log. If there are any unresolved issues remaining after signing off on the timecard in the system, the issues will be documented along with the manager?s actions. The ultimate goal is to obtain management approval for every timecard, whether such approval is documented directly within the automated payroll system prior to sign-off or documented outside of the system after sign-off. As is always the case, if adjustments to a timecard are necessary after the sign-off process, the OHRM will utilize their ?OHRM-36 Kronos Time & Leave Correction" form. When deemed necessary, the log and any related documentation will be shared with the state?s independent auditors during fieldwork for the West Virginia Single Audit. The anticipated date for completion of the log and the procedures related thereto is February 10, 2023. For the condition whereby the payroll system was unavailable due to a ransomware attack, the OHRM switched to a manual timekeeping system immediately after the attack and developed processes and controls related thereto. However, as the state?s independent auditors indicated, the OHRM did not maintain adequate documentation related to the controls and the precision of the controls in all instances. Accordingly, the OHRM is working on a contingency plan to document the steps to take in the event of another ransomware attack or any other incident that causes the automated payroll system to be unavailable. The anticipated date for completion is March 31, 2023.

View Audit 40967

Finding 46204 (2022-001)

Material Weakness 2022

State of West Virginia

WV

Allowable Costs / Cost Principles Eligibility Internal Control / Segregation of Duties § 200.303

DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561, 10.542, 93.558, COVID-19 93.558, 93.568, COVID-19 93.568, 93.575, 93.596, COVID-19 93.575, 93.658, 93.659, 93.767, 93.775, 93.777, ...

DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561, 10.542, 93.558, COVID-19 93.558, 93.568, COVID-19 93.568, 93.575, 93.596, COVID-19 93.575, 93.658, 93.659, 93.767, 93.775, 93.777, COVID-19 93.777, 93.778, COVID-19 93.778, ARRA 93.778 Enhancing the Quality Control process (by adding other programs to the overall scope and expanding the populations for sampling to include payments that have case data that is initiated and approved by the same person as well as case data that is entered by one person without another level of approval) would prove costly for the DHHR due to the additional staff throughout the DHHR that would be required to accomplish such a task. Although enhancing the Quality Control process is still a possibility, upon further discussions within the DHHR, it was determined that prior to considering such an enhancement, the Bureau for Social Services, Bureau for Family Assistance, and other DHHR units should work together to perform the following: outline the existing internal controls over payments by payment type or program, determine the number of payments per month whereby one employee initiates and approves a payment (in relation to the population of all payments) and conclude on the risk of those payments being improper. Management can then identify areas of focus to conclude on the adequacy of the internal controls and make revisions to policies and procedures, if necessary. In short, although there are existing controls in place, the controls have not been documented and communicated to the State?s independent auditors in an effective manner.

View Audit 40967

Finding 46203 (2022-001)

None 2022

Rudolphy/mercy Douglass Home for the Blind

PA

(Insert Corrective Action Plan for 2022)

View Audit 40992

Finding 46202 (2022-002)

Material Weakness 2022

Schoolcraft College

MI

Allowable Costs / Cost Principles

Finding Number: 2022-002 Condition: The College did not obtain affirmative written consent from students before using emergency financial aid grants to satisfy a student's outstanding account balance. Planned Corrective Action: The grant funding applied incorrectly as a result of this finding has be...

Finding Number: 2022-002 Condition: The College did not obtain affirmative written consent from students before using emergency financial aid grants to satisfy a student's outstanding account balance. Planned Corrective Action: The grant funding applied incorrectly as a result of this finding has been returned to the Department of Education. The amount of the grant funding returned was $2,707,692. In response to this finding, the College?s current Financial Aid Director, Chief Counsel, Chief Student Enrollment Officer, and Chief Financial Officer developed remedial action to implement an appropriate application process to obtain affirmative consent from all students on future application of grant monies to outstanding tuition balances. This new process was implemented as of August 17, 2022, and forward. To ensure compliance, the student grant application now includes functionality that requires positive affirmative consent from all applying students before grant monies are applied to an outstanding tuition balance. Now that the updated application is live on the College?s scholarship website, the College is currently accepting applications for the remainder of the award and only applying the funds to student accounts with the student?s affirmative consents. If students select either the tuition & fees or prior balances selections, funds will be applied to their outstanding tuition balance accordingly. If students do not affirmatively select either of these options, the funds will be distributed directly to the student as an emergency grant. Contact person responsible for corrective action: Lisa Brooker (Director of Financial Aid) Anticipated Completion Date: August 17, 2022

View Audit 40764

Finding 46195 (2022-001)

Material Weakness 2022

Chehalis School District No. 302

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of School District contact person: Heather C. Pinkerton 310 SW 16th St Chehalis, WA 98532 360-807-7207 Corrective actio...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of School District contact person: Heather C. Pinkerton 310 SW 16th St Chehalis, WA 98532 360-807-7207 Corrective action the auditee plans to take in response to the finding: It is highly unusual for the district to utilize federal funds for construction projects; the Covid-19 Education Stabilization Funds were an anomaly. The District?s Director of Business and Operations was unaware that prevailing wage clauses are required to be included in all public works contracts over $2,000 that are paid with federal funds. She was aware that prevailing wages need to be paid. The audit finding does not dispute that prevailing wages were paid appropriately, just that the clauses were not included in the contracts. To be very clear, this finding is for not having required language in contracts. The District is now aware that inclusion of the clauses is a compliance requirement. Going forward, it is unlikely that federal funds will be used for construction projects; however, when federal funds are utilized for construction projects, the District will either include the required prevailing wage rate clauses in its contracts or will obtain a separate signed clause with the required prevailing wage rate information. Anticipated date to complete the corrective action: Immediately

View Audit 40903

Finding 46194 (2022-002)

Material Weakness 2022

Chehalis School District No. 302

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of School District contact person: Heather C. Pinkerton 310 SW 16th St Cheh...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of School District contact person: Heather C. Pinkerton 310 SW 16th St Chehalis, WA 98532 360-807-7207 Corrective action the auditee plans to take in response to the finding: The Chehalis School District does not concur with the finding or the questioned costs. The State Auditor?s Office (SAO) reviewed various types of documentation and did not accept documentation presented by the District to reduce or eliminate questioned costs. The standard of documentation required by SAO to satisfy ?unmet need? would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We continue to communicate with other agencies with the ultimate goal of helping the Federal Communications Commission (FCC) understand that they should not seek any recovery of funds resulting from ?documentation? issues considering the massive public health response, deployment logistics, vague federal guidance, and the effective return to in-person learning. Along with countless other districts across the State of Washington, we look forward to working with the FCC to resolve this finding. We appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? Corrective action the auditee plans to take in response to the finding: The Chehalis School District does not concur with the finding or the questioned costs. The State Auditor?s Office (SAO) reviewed various types of documentation and did not accept documentation presented by the District to reduce or eliminate questioned costs. The standard of documentation required by SAO to satisfy ?unmet need? would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We continue to communicate with other agencies with the ultimate goal of helping the Federal Communications Commission (FCC) understand that they should not seek any recovery of funds resulting from ?documentation? issues considering the massive public health response, deployment logistics, vague federal guidance, and the effective return to in-person learning. Along with countless other districts across the State of Washington, we look forward to working with the FCC to resolve this finding. We appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? Anticipated date to complete the corrective action: We will work with the FCC to resolve this issue according to their timeline.

View Audit 40903 Questioned Costs: $1

Finding 46193 (2022-001)

Material Weakness 2022

Louisiana Human Resources Dev. Institute

LA

Internal Control / Segregation of Duties

Management has noted this condition and has determined that the cost necessary to establish adequate segregation of duties is not justifiable at this time.

View Audit 40865

Finding 46192 (2022-002)

Significant Deficiency 2022

Town of Westport, Conencticut

CT

Procurement, Suspension & Debarment Subrecipient Monitoring

FINDING - FEDERAL AWARD PROGRAMS AUDIT United States Department of the Treasury 2022-002 COVID-19 American Rescue Plan Act Local Fiscal Recovery ? AL No. 21.027 Recommendation: We recommend that the policies be updated to include that vendors will be reviewed to ensure they are not suspended and ...

FINDING - FEDERAL AWARD PROGRAMS AUDIT United States Department of the Treasury 2022-002 COVID-19 American Rescue Plan Act Local Fiscal Recovery ? AL No. 21.027 Recommendation: We recommend that the policies be updated to include that vendors will be reviewed to ensure they are not suspended and debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management further notes that it will review all vendors through the Sam website to verify that the vendor has not been debarred or ineligible from receiving Federal Government funds. Name of the contact person responsible for corrective action: Sheila Carey Planned completion date for corrective action plan: March 30, 2023.

View Audit 40828

Finding 46191 (2022-001)

Significant Deficiency 2022

Town of Westport, Conencticut

CT

Internal Control / Segregation of Duties Reporting Significant Deficiency

FINDING - FEDERAL AWARD PROGRAMS AUDIT United States Department of the Treasury 2022-001 COVID-19 American Rescue Plan Act Local Fiscal Recovery ? AL No. 21.027 Recommendation: We recommend that the Town implement a control for the Project and Expenditure Report to be reviewed by an individual ind...

FINDING - FEDERAL AWARD PROGRAMS AUDIT United States Department of the Treasury 2022-001 COVID-19 American Rescue Plan Act Local Fiscal Recovery ? AL No. 21.027 Recommendation: We recommend that the Town implement a control for the Project and Expenditure Report to be reviewed by an individual independent of the preparation process prior to submission to the Treasury. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with this finding. Management further notes that a two-step review process has been implemented where the Controller will review the documents sign-off before the Finance Directors submits them through the State portal. The of the contact person responsible for corrective action: Sheila Carey Planned completion date for corrective action plan: March 30, 2023.

View Audit 40828

Finding 46189 (2022-006)

Significant Deficiency 2022

Northwest Iowa Mental Health Center D/b/a Seasons Center for Community

IA

Reporting Significant Deficiency § 200.303 § 200.328 § 200.329

Finding 2022-006: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Through testing of one programmatic report, the number of adults and children served du...

Finding 2022-006: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Through testing of one programmatic report, the number of adults and children served during the reporting period included six individuals twice. As a result of a software change during the grant year, management combined the listing of adults and children served from two electronic health record systems and did not identify these six individuals were duplicates in the listings. Responsible Individuals: Project Directors (Missy Martini, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review reports prior to submission and will do random testing of numbers included in the report to ensure numbers reported have supporting documentation. Documentation used to complete the required reports will be retained by the Center. Anticipated Completion Date: This process was implemented beginning January 2023.

View Audit 41794

Finding 46188 (2022-005)

Material Weakness 2022

Northwest Iowa Mental Health Center D/b/a Seasons Center for Community

IA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Finding 2022-005: Activities Allowed and Allowable Costs Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Employees did not enter all nonfederal hours within the Cl...

Finding 2022-005: Activities Allowed and Allowable Costs Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. The Center?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. A sample of expenditures selected for testing, noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (7 instances). b) Calculation errors for expenses allocated to the grant (2 instances). Responsible Individuals: Staff Supervisors (Abbie Tesch, Amber Utesch, Christina Eggink-Postma, Karen Rosengreen, Jason Low, Missy Martini, Rebecca McCrackin, Sarah Heinrichs, Stephanie Pohar) and Project Accounts Manager (Marsha Bomgaars) Corrective Action Plan: Staff supervisors are to compare ClickTime entries with payroll system entries to ensure they match. The Project Accounts Manager will compare all ClickTime reports and payroll reports to ensure they match and are accurate. Anticipated Completion Date: In November 2022, the Center began reconciling ClickTime reports with payroll reports using an excel spreadsheet to identify discrepancies between the ClickTime timecards and the payroll register to help ensure all hours are accurately reported.

View Audit 41794

Finding 46187 (2022-007)

Significant Deficiency 2022

Northwest Iowa Mental Health Center D/b/a Seasons Center for Community

IA

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.327

Finding 2022-007: Procurement, Suspension, and Debarment Federal Agency Name: Department of Health and Human Services CFDA #93.087& 93.829 Program Name: Enhance Safety of Children Affected by Substance Abuse & Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Su...

Finding 2022-007: Procurement, Suspension, and Debarment Federal Agency Name: Department of Health and Human Services CFDA #93.087& 93.829 Program Name: Enhance Safety of Children Affected by Substance Abuse & Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Testing identified one contract for each of the above programs where the required contract provisions in accordance with Uniform Guidance were not included within the contract over $25,000. In addition, no documentation was retained to support management?s rationale to select both of these contracted vendors. Responsible Individuals: Project Directors (Christina Eggink-Postma, Sarah Heinrichs, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review contracts to ensure proper contract provisions are included in accordance with Uniform Guidance and the Center?s procurement policy. The CEO will document what has been reviewed and whether or not the contract has all the necessary contract requirements before contracts are executed. Anticipated Completion Date: This process was implemented beginning January 2023.

View Audit 41794

Corrective Action Plans

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