2022-006 Department of Health and Human Services FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. Condition: Through testing of one programmatic report, we noted the number of adults and children served during the reporting period included six individuals twice. Cause: 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. Effect: The programmatic report included a total of six adults and children serviced during the reporting period twice. Questioned Costs: None reported. Context: Included under the award letter of the federal program, one annual federal financial report and one annual programmatic progress report was reviewed in the Center?s fiscal year. There was a total of 5 reports filed. Repeat Finding from Prior Year: Yes, prior year finding 2021-006 Recommendation: We recommend management review the procedures and control processes surrounding preparation and review of reports to ensure reports are completed based upon supporting documentation. View of Responsible Officials: Management is in agreement.
2022-007 Department of Health and Human Services FFLA #93.087, 90CU0090, 9/30/2020 ? 9/29/2022 Enhance Safety of Children Affected by Substance Abuse FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CRF 200.318 through 200.327 which also requires documentation to be retained to detail the history of procurements. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. Condition: During testing, we identified one contract for each of the above FFLA?s where the required contract provisions in accordance with Uniform Guidance were not included within a contract over $25,000. In addition, no documentation was retained to support management?s rationale to select both of these contracted vendors. Cause: Contract provisions were not evaluated compared to Uniform Guidance contract requirements and documentation was not retained to support management?s rationale to select two contracted vendors. Effect: Contracts may be entered into with a vendor who is suspended or debarred, and contracts may not be in compliance with Uniform Guidance if required contract provisions are not included within the contract. In addition, it is hard to demonstrate that the program complies with laws, regulations, and other compliance requirements when documentation is not retained. Questioned Costs: None reported Context: There was only one contract above the $10,000 procurement policy threshold under the Enhance Safety of Children Affected by Substance Abuse program which was fully tested. There was a total of four contracts above the $10,000 procurement policy threshold under the Section 223 Demonstration Programs to Improve Community Mental Health Services program and two contracts were tested. Repeat Finding from Prior Year: Yes, prior year finding 2021-007 Recommendation: We recommend that management review the procedures and control processes to ensure contract include the required Uniform Guidance provisions and documentation is retained to support the rationale for selecting vendors during the procurement process. Views of Responsible Officials: Management is in agreement.
2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Agriculture Supplemental Nutrition Assistance Program (SNAP) 10.551/10.561/ COVID-19 10.561 Grant Award 1WV400401 Grant Award 1WV400468 Grant Award 1WV430459 Grant Award 1WV430469 Grant Award 1WV460479 Pandemic EBT Food Benefits (P-EBT) 10.542 U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2021G990228 Grant Award 2022G996115 Low-Income Home Energy Assistance 93.568/ COVID19 93.568 Grant Award 2001WVLIE4 Grant Award 2101WVLIEA Grant Award 2101WVE5C6 Grant Award 2201WVLIEA Grant Award 2201 WVLIEI Grant Award 2001WVE5C3 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID19 93.575 Grant Award 2101WVCCDF Grant Award 2101WVCCDM Grant Award 2101WVCCDD Grant Award 2201WVCCDF Grant Award 2201WVCCDM Grant Award 2201WVCCDD Foster Care ? Title IV-E 93.658 Grant Award 2101WVFOST Grant Award 2201WVFOST Adoption Assistance ? Title IV-E 93.659 Grant Award 2101WVADPT Grant Award 2201WVADPT Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021 Medicaid Cluster 93.775/93.777/ COVID-19 93.777/ 93.778/ ARRA 93.778 Grant Award 2105WV5MAP Grant Award 2105WV5ADM Grant Award 2105WVIMPL Grant Award 2105WVINCT Grant Award 2205WV5MAP Grant Award 2205WV5ADM Grant Award 2205WVIMPL Grant Award 2205WVINCTCriteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Family and Children Tracking System (FACTS): West Virginia Department of Health and Human Resources (DHHR) operates a wide variety of computer applications, many of which affect federal and State programs? data. Our review of the information system controls noted that adequate segregation of duties does not exist for the FACTS information system. Certain users have the ability to both create and approve cases. We noted that management implemented a mitigating detect control for the Foster Care program during fiscal year 2012 in response to this repeat finding; however, it was not designed to encompass the Adoption Assistance program or automatic payments in the Foster Care program. Additionally, no supervisory review is required for provider payment information input into the system. Recipient Automated Payment Information Data System (RAPIDS): Application Suite: Our testing of the controls surrounding eligibility determination noted that adequate segregation of duties does not exist for the RAPIDS system. No supervisory review is required for case information input into the system. Further, it was noted that approval of disbursements only occurs at the batch level, which does not allow the approval worker to review each transaction individually. Questioned Costs: N/A Context: Total federal expenditures for these programs can be located in the Schedule of Expenditures of Federal Awards. The table below identifies the federal programs and compliance requirements impacted. ?See Schedule of Findings and Questioned Costs for char/table? Cause: Policies and procedures have not been adequately updated for changes in the processing of eligibility determinations. Furthermore, management indicated that a lack of personnel resources contributes to the improper segregation of duties issue. Effect: Without proper segregation of duties or adequate detect controls, the ability exists for certain information system users to create and approve cases and demand payments within the FACTS application. Information can be input into the FACTS application or modified within the application without supervisory review, which could lead to payments being made to ineligible applicants, for the improper amount, or for an improper length of time. Without proper segregation of duties or adequate detect controls, the ability exists for case workers to input unsupported information into an applicant?s eligibility calculation within RAPIDS. Further, without supervisory review at the transactional level, disbursements for unallowable costs or activities could occur. 2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) (continued) Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. We recommend that access to various FACTS system applications be restricted to a limited number of users. Controls should be established to ensure that an individual is limited to either creating or approving cases or payments. A detect control should be implemented that would require a review of all individual cases and payments with the same request and approval worker to ensure that cases and payments created and approved were appropriate. Further, we recommend that a formal review process be implemented to ensure that information input into FACTS and RAPIDS is properly reviewed by authorized individuals prior to payment. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Agriculture Supplemental Nutrition Assistance Program (SNAP) 10.551/10.561/ COVID-19 10.561 Grant Award 1WV400401 Grant Award 1WV400468 Grant Award 1WV430459 Grant Award 1WV430469 Grant Award 1WV460479 Pandemic EBT Food Benefits (P-EBT) 10.542 U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2021G990228 Grant Award 2022G996115 Low-Income Home Energy Assistance 93.568/ COVID19 93.568 Grant Award 2001WVLIE4 Grant Award 2101WVLIEA Grant Award 2101WVE5C6 Grant Award 2201WVLIEA Grant Award 2201 WVLIEI Grant Award 2001WVE5C3 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID19 93.575 Grant Award 2101WVCCDF Grant Award 2101WVCCDM Grant Award 2101WVCCDD Grant Award 2201WVCCDF Grant Award 2201WVCCDM Grant Award 2201WVCCDD Foster Care ? Title IV-E 93.658 Grant Award 2101WVFOST Grant Award 2201WVFOST Adoption Assistance ? Title IV-E 93.659 Grant Award 2101WVADPT Grant Award 2201WVADPT Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021 Medicaid Cluster 93.775/93.777/ COVID-19 93.777/ 93.778/ ARRA 93.778 Grant Award 2105WV5MAP Grant Award 2105WV5ADM Grant Award 2105WVIMPL Grant Award 2105WVINCT Grant Award 2205WV5MAP Grant Award 2205WV5ADM Grant Award 2205WVIMPL Grant Award 2205WVINCTCriteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Family and Children Tracking System (FACTS): West Virginia Department of Health and Human Resources (DHHR) operates a wide variety of computer applications, many of which affect federal and State programs? data. Our review of the information system controls noted that adequate segregation of duties does not exist for the FACTS information system. Certain users have the ability to both create and approve cases. We noted that management implemented a mitigating detect control for the Foster Care program during fiscal year 2012 in response to this repeat finding; however, it was not designed to encompass the Adoption Assistance program or automatic payments in the Foster Care program. Additionally, no supervisory review is required for provider payment information input into the system. Recipient Automated Payment Information Data System (RAPIDS): Application Suite: Our testing of the controls surrounding eligibility determination noted that adequate segregation of duties does not exist for the RAPIDS system. No supervisory review is required for case information input into the system. Further, it was noted that approval of disbursements only occurs at the batch level, which does not allow the approval worker to review each transaction individually. Questioned Costs: N/A Context: Total federal expenditures for these programs can be located in the Schedule of Expenditures of Federal Awards. The table below identifies the federal programs and compliance requirements impacted. ?See Schedule of Findings and Questioned Costs for char/table? Cause: Policies and procedures have not been adequately updated for changes in the processing of eligibility determinations. Furthermore, management indicated that a lack of personnel resources contributes to the improper segregation of duties issue. Effect: Without proper segregation of duties or adequate detect controls, the ability exists for certain information system users to create and approve cases and demand payments within the FACTS application. Information can be input into the FACTS application or modified within the application without supervisory review, which could lead to payments being made to ineligible applicants, for the improper amount, or for an improper length of time. Without proper segregation of duties or adequate detect controls, the ability exists for case workers to input unsupported information into an applicant?s eligibility calculation within RAPIDS. Further, without supervisory review at the transactional level, disbursements for unallowable costs or activities could occur. 2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) (continued) Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. We recommend that access to various FACTS system applications be restricted to a limited number of users. Controls should be established to ensure that an individual is limited to either creating or approving cases or payments. A detect control should be implemented that would require a review of all individual cases and payments with the same request and approval worker to ensure that cases and payments created and approved were appropriate. Further, we recommend that a formal review process be implemented to ensure that information input into FACTS and RAPIDS is properly reviewed by authorized individuals prior to payment. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Agriculture Supplemental Nutrition Assistance Program (SNAP) 10.551/10.561/ COVID-19 10.561 Grant Award 1WV400401 Grant Award 1WV400468 Grant Award 1WV430459 Grant Award 1WV430469 Grant Award 1WV460479 Pandemic EBT Food Benefits (P-EBT) 10.542 U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2021G990228 Grant Award 2022G996115 Low-Income Home Energy Assistance 93.568/ COVID19 93.568 Grant Award 2001WVLIE4 Grant Award 2101WVLIEA Grant Award 2101WVE5C6 Grant Award 2201WVLIEA Grant Award 2201 WVLIEI Grant Award 2001WVE5C3 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID19 93.575 Grant Award 2101WVCCDF Grant Award 2101WVCCDM Grant Award 2101WVCCDD Grant Award 2201WVCCDF Grant Award 2201WVCCDM Grant Award 2201WVCCDD Foster Care ? Title IV-E 93.658 Grant Award 2101WVFOST Grant Award 2201WVFOST Adoption Assistance ? Title IV-E 93.659 Grant Award 2101WVADPT Grant Award 2201WVADPT Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021 Medicaid Cluster 93.775/93.777/ COVID-19 93.777/ 93.778/ ARRA 93.778 Grant Award 2105WV5MAP Grant Award 2105WV5ADM Grant Award 2105WVIMPL Grant Award 2105WVINCT Grant Award 2205WV5MAP Grant Award 2205WV5ADM Grant Award 2205WVIMPL Grant Award 2205WVINCTCriteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Family and Children Tracking System (FACTS): West Virginia Department of Health and Human Resources (DHHR) operates a wide variety of computer applications, many of which affect federal and State programs? data. Our review of the information system controls noted that adequate segregation of duties does not exist for the FACTS information system. Certain users have the ability to both create and approve cases. We noted that management implemented a mitigating detect control for the Foster Care program during fiscal year 2012 in response to this repeat finding; however, it was not designed to encompass the Adoption Assistance program or automatic payments in the Foster Care program. Additionally, no supervisory review is required for provider payment information input into the system. Recipient Automated Payment Information Data System (RAPIDS): Application Suite: Our testing of the controls surrounding eligibility determination noted that adequate segregation of duties does not exist for the RAPIDS system. No supervisory review is required for case information input into the system. Further, it was noted that approval of disbursements only occurs at the batch level, which does not allow the approval worker to review each transaction individually. Questioned Costs: N/A Context: Total federal expenditures for these programs can be located in the Schedule of Expenditures of Federal Awards. The table below identifies the federal programs and compliance requirements impacted. ?See Schedule of Findings and Questioned Costs for char/table? Cause: Policies and procedures have not been adequately updated for changes in the processing of eligibility determinations. Furthermore, management indicated that a lack of personnel resources contributes to the improper segregation of duties issue. Effect: Without proper segregation of duties or adequate detect controls, the ability exists for certain information system users to create and approve cases and demand payments within the FACTS application. Information can be input into the FACTS application or modified within the application without supervisory review, which could lead to payments being made to ineligible applicants, for the improper amount, or for an improper length of time. Without proper segregation of duties or adequate detect controls, the ability exists for case workers to input unsupported information into an applicant?s eligibility calculation within RAPIDS. Further, without supervisory review at the transactional level, disbursements for unallowable costs or activities could occur. 2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) (continued) Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. We recommend that access to various FACTS system applications be restricted to a limited number of users. Controls should be established to ensure that an individual is limited to either creating or approving cases or payments. A detect control should be implemented that would require a review of all individual cases and payments with the same request and approval worker to ensure that cases and payments created and approved were appropriate. Further, we recommend that a formal review process be implemented to ensure that information input into FACTS and RAPIDS is properly reviewed by authorized individuals prior to payment. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Agriculture Supplemental Nutrition Assistance Program (SNAP) 10.551/10.561/ COVID-19 10.561 Grant Award 1WV400401 Grant Award 1WV400468 Grant Award 1WV430459 Grant Award 1WV430469 Grant Award 1WV460479 Pandemic EBT Food Benefits (P-EBT) 10.542 U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2021G990228 Grant Award 2022G996115 Low-Income Home Energy Assistance 93.568/ COVID19 93.568 Grant Award 2001WVLIE4 Grant Award 2101WVLIEA Grant Award 2101WVE5C6 Grant Award 2201WVLIEA Grant Award 2201 WVLIEI Grant Award 2001WVE5C3 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID19 93.575 Grant Award 2101WVCCDF Grant Award 2101WVCCDM Grant Award 2101WVCCDD Grant Award 2201WVCCDF Grant Award 2201WVCCDM Grant Award 2201WVCCDD Foster Care ? Title IV-E 93.658 Grant Award 2101WVFOST Grant Award 2201WVFOST Adoption Assistance ? Title IV-E 93.659 Grant Award 2101WVADPT Grant Award 2201WVADPT Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021 Medicaid Cluster 93.775/93.777/ COVID-19 93.777/ 93.778/ ARRA 93.778 Grant Award 2105WV5MAP Grant Award 2105WV5ADM Grant Award 2105WVIMPL Grant Award 2105WVINCT Grant Award 2205WV5MAP Grant Award 2205WV5ADM Grant Award 2205WVIMPL Grant Award 2205WVINCTCriteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Family and Children Tracking System (FACTS): West Virginia Department of Health and Human Resources (DHHR) operates a wide variety of computer applications, many of which affect federal and State programs? data. Our review of the information system controls noted that adequate segregation of duties does not exist for the FACTS information system. Certain users have the ability to both create and approve cases. We noted that management implemented a mitigating detect control for the Foster Care program during fiscal year 2012 in response to this repeat finding; however, it was not designed to encompass the Adoption Assistance program or automatic payments in the Foster Care program. Additionally, no supervisory review is required for provider payment information input into the system. Recipient Automated Payment Information Data System (RAPIDS): Application Suite: Our testing of the controls surrounding eligibility determination noted that adequate segregation of duties does not exist for the RAPIDS system. No supervisory review is required for case information input into the system. Further, it was noted that approval of disbursements only occurs at the batch level, which does not allow the approval worker to review each transaction individually. Questioned Costs: N/A Context: Total federal expenditures for these programs can be located in the Schedule of Expenditures of Federal Awards. The table below identifies the federal programs and compliance requirements impacted. ?See Schedule of Findings and Questioned Costs for char/table? Cause: Policies and procedures have not been adequately updated for changes in the processing of eligibility determinations. Furthermore, management indicated that a lack of personnel resources contributes to the improper segregation of duties issue. Effect: Without proper segregation of duties or adequate detect controls, the ability exists for certain information system users to create and approve cases and demand payments within the FACTS application. Information can be input into the FACTS application or modified within the application without supervisory review, which could lead to payments being made to ineligible applicants, for the improper amount, or for an improper length of time. Without proper segregation of duties or adequate detect controls, the ability exists for case workers to input unsupported information into an applicant?s eligibility calculation within RAPIDS. Further, without supervisory review at the transactional level, disbursements for unallowable costs or activities could occur. 2022?001 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS (Repeat of Prior Year Findings 2021?001, 2020?023, 2019?027, 2018?017, 2017?002, 2016?017, 2015?025, 2014?016, 2013?034, 2012?51, 2011?46, 2010?43, 2009?43, and 2008?55) (continued) Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. We recommend that access to various FACTS system applications be restricted to a limited number of users. Controls should be established to ensure that an individual is limited to either creating or approving cases or payments. A detect control should be implemented that would require a review of all individual cases and payments with the same request and approval worker to ensure that cases and payments created and approved were appropriate. Further, we recommend that a formal review process be implemented to ensure that information input into FACTS and RAPIDS is properly reviewed by authorized individuals prior to payment. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?004 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Child Nutrition Cluster 10.553/10.555/ 10.556/10.559/ 10.582Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: The West Virginia Department of Education is a prime recipient of funding for the Child Nutrition Cluster and made first tier subawards of greater than $30,000 but did not file any of the necessary Federal Funding Accountability and Transparency Act (FFATA) reports. Questioned Costs: N/A Context: Subawards for the Child Nutrition Cluster program included 316 subawards that totaled $185,593,250 for the year ended June 30, 2022. Total expenditures for the Child Nutrition Cluster program were $194,300,763 for the year ended June 30, 2022. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect: West Virginia Department of Education management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System. Recommendation: We recommend that West Virginia Department of Education management take immediate action to ensure compliance with the reporting requirements of the FFATA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?004 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Child Nutrition Cluster 10.553/10.555/ 10.556/10.559/ 10.582Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: The West Virginia Department of Education is a prime recipient of funding for the Child Nutrition Cluster and made first tier subawards of greater than $30,000 but did not file any of the necessary Federal Funding Accountability and Transparency Act (FFATA) reports. Questioned Costs: N/A Context: Subawards for the Child Nutrition Cluster program included 316 subawards that totaled $185,593,250 for the year ended June 30, 2022. Total expenditures for the Child Nutrition Cluster program were $194,300,763 for the year ended June 30, 2022. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect: West Virginia Department of Education management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System. Recommendation: We recommend that West Virginia Department of Education management take immediate action to ensure compliance with the reporting requirements of the FFATA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?004 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Child Nutrition Cluster 10.553/10.555/ 10.556/10.559/ 10.582Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: The West Virginia Department of Education is a prime recipient of funding for the Child Nutrition Cluster and made first tier subawards of greater than $30,000 but did not file any of the necessary Federal Funding Accountability and Transparency Act (FFATA) reports. Questioned Costs: N/A Context: Subawards for the Child Nutrition Cluster program included 316 subawards that totaled $185,593,250 for the year ended June 30, 2022. Total expenditures for the Child Nutrition Cluster program were $194,300,763 for the year ended June 30, 2022. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect: West Virginia Department of Education management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System. Recommendation: We recommend that West Virginia Department of Education management take immediate action to ensure compliance with the reporting requirements of the FFATA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?004 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Child Nutrition Cluster 10.553/10.555/ 10.556/10.559/ 10.582Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: The West Virginia Department of Education is a prime recipient of funding for the Child Nutrition Cluster and made first tier subawards of greater than $30,000 but did not file any of the necessary Federal Funding Accountability and Transparency Act (FFATA) reports. Questioned Costs: N/A Context: Subawards for the Child Nutrition Cluster program included 316 subawards that totaled $185,593,250 for the year ended June 30, 2022. Total expenditures for the Child Nutrition Cluster program were $194,300,763 for the year ended June 30, 2022. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect: West Virginia Department of Education management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System. Recommendation: We recommend that West Virginia Department of Education management take immediate action to ensure compliance with the reporting requirements of the FFATA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?004 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Child Nutrition Cluster 10.553/10.555/ 10.556/10.559/ 10.582Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: The West Virginia Department of Education is a prime recipient of funding for the Child Nutrition Cluster and made first tier subawards of greater than $30,000 but did not file any of the necessary Federal Funding Accountability and Transparency Act (FFATA) reports. Questioned Costs: N/A Context: Subawards for the Child Nutrition Cluster program included 316 subawards that totaled $185,593,250 for the year ended June 30, 2022. Total expenditures for the Child Nutrition Cluster program were $194,300,763 for the year ended June 30, 2022. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect: West Virginia Department of Education management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System. Recommendation: We recommend that West Virginia Department of Education management take immediate action to ensure compliance with the reporting requirements of the FFATA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?005 TRANSPARENCY ACT REPORTING (Repeat of Prior Year Finding 2021?002) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Housing and Urban Development Community Development Block Grants/State?s Program and Non-Entitlement Gants in Hawaii 14.228/ COVID-19 14.228 Grant Award B14DC540001 Grant Award B16DL540001 #2 Grant Award B15DC540001 Grant Award B16DC540001 Grant Award B17DC540001 Grant Award B18DC540001 Grant Award B19DC540001 Grant Award B20DC540001 Grant Award B20DW540001 Grant Award B21DC540001Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: During our testing of Federal Funding Accountability and Transparency Act (FFATA) Reports, it was noted that the reports were not submitted by the State of West Virginia Community Development Block Grant program management within the timeframe designated in 2 CFR 170 Appendix A. ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the CDBG program included 22 subawards that totaled $15,177,456 for the year ended June 30, 2022. The five subawards tested that were not reported to the FFATA Subaward Reporting System timely was $7,119,797. Total expenditures for the CDBG program were $25,867,297 for the year ended June 30, 2022. Cause: A lack of oversight and adequate review of the FFATA reporting requirements by CDBG management caused the reports required for first tier subawards over $30,000 to not be submitted timely to the FFATA Subaward Reporting System, and to have missing/incorrect information reported. Effect: CDBG management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System accurately or in a timely fashion Recommendation: We recommend that CDBG management take immediate action to ensure compliance with the reporting requirements of the FFATA, which includes the timely submission of the reports and accurate information Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?005 TRANSPARENCY ACT REPORTING (Repeat of Prior Year Finding 2021?002) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Housing and Urban Development Community Development Block Grants/State?s Program and Non-Entitlement Gants in Hawaii 14.228/ COVID-19 14.228 Grant Award B14DC540001 Grant Award B16DL540001 #2 Grant Award B15DC540001 Grant Award B16DC540001 Grant Award B17DC540001 Grant Award B18DC540001 Grant Award B19DC540001 Grant Award B20DC540001 Grant Award B20DW540001 Grant Award B21DC540001Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 170 Appendix A, ?unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.? Condition: During our testing of Federal Funding Accountability and Transparency Act (FFATA) Reports, it was noted that the reports were not submitted by the State of West Virginia Community Development Block Grant program management within the timeframe designated in 2 CFR 170 Appendix A. ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the CDBG program included 22 subawards that totaled $15,177,456 for the year ended June 30, 2022. The five subawards tested that were not reported to the FFATA Subaward Reporting System timely was $7,119,797. Total expenditures for the CDBG program were $25,867,297 for the year ended June 30, 2022. Cause: A lack of oversight and adequate review of the FFATA reporting requirements by CDBG management caused the reports required for first tier subawards over $30,000 to not be submitted timely to the FFATA Subaward Reporting System, and to have missing/incorrect information reported. Effect: CDBG management did not report the necessary FFATA reports for first tier subawards over $30,000 to The FFATA Subaward Reporting System accurately or in a timely fashion Recommendation: We recommend that CDBG management take immediate action to ensure compliance with the reporting requirements of the FFATA, which includes the timely submission of the reports and accurate information Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?006 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Repeat of Prior Year Findings 2021?004 and 2020?002) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Labor Unemployment Insurance (UI) 17.225 Grant Award UI-35683-21-55-A-54 Grant Award UI-37314-22-55-A-54 Grant Award UI-34749-20-55-A-54 Grant Award UI-35978-21-60-A-54 Grant Award UI-37099-21-55-A-54 Grant Award UI-37257-22-55-A-54Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.508(b) states, ?The auditee must prepare appropriate financial statements, including the schedule of expenditures of Federal awards.? The Federal Office of Management and Budget issues instructions on how to prepare this schedule. Condition: Workforce West Virginia?s (WWV?s) internal controls are not adequate to ensure that the Schedule of Expenditures Federal Awards (SEFA) accurately reports all federal assistance. It was noted the SEFA was resubmitted due to errors causing untimely submission. Questioned Costs: N/A Context: Total federal disbursements for the Unemployment Insurance (UI) were $307,154,978 for the year ended June 30, 2022. Cause: The internal controls over the SEFA reporting processes were not adequately enforced to ensure the SEFA is accurate due to lack of training. Effect: WWV is not properly reporting their federal expenditures and type A programs may not be appropriately identified on a timely basis. Recommendation: We recommend that WWV ensure staff responsible for the preparation of the SEFA have the resources needed to accurately prepare the SEFA. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?007 REPORTING, AND MATCHING, LEVEL OF EFFORT, EARMARKING (Repeat of Prior Year Findings 2021?006 and 2020?005) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Labor Unemployment Insurance (UI) 17.225 Grant Award UI-35683-21-55-A-54 Grant Award UI-37314-22-55-A-54 Grant Award UI-34749-20-55-A-54 Grant Award UI-35978-21-60-A-54 Grant Award UI-37099-21-55-A-54 Grant Award UI-37257-22-55-A-54Criteria: 2 CFR 200.303 requires that the non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: During our testing of four ETA 2112 reports submitted, we noted that during the compliance year, management resubmitted three of the reports due to Workforce West Virginia (WWV) not initially following United States Department of Labor guidance related to program classifications. Additionally, the following reports tested were not reviewed and approved prior to submission: 1) two of the two ETA 2208A reports 2) one of the three ETA 9050 reports 3) two of the four ETA 9052 reports 4) two of the four ETA 9055 reports, and 5) one of the two ETA 9128 reports. In addition, one of the two ETA 9128 reports was revised and submitted by the approver. The review and approval of the ETA 2112 is also the control for the matching compliance requirement. Questioned Costs: N/A Context: Total federal disbursements for the Unemployment Insurance (UI) program were $307,154,978 for the year ended June 30, 2022. Cause: The internal controls over the individual reporting processes were not adequately enforced or documented. Effect: Reports could be filed with errors or lack of supporting documentation and not be identified by management. The matching requirement may not be met. Recommendation: We recommend that WWV implement internal controls over the report submission process, to ensure each report is reviewed and approved by appropriate individuals familiar with the reporting requirements to ensure that accurate information is reported. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?008 INTERNAL CONTROLS OVER INFORMATION TECHNOLOGY (Repeat of Prior Year Findings 2021?005 and 2020?003) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Labor Unemployment Insurance (UI) 17.225 Grant Award UI-35683-21-55-A-54 Grant Award UI-37314-22-55-A-54 Grant Award UI-34749-20-55-A-54 Grant Award UI-35978-21-60-A-54 Grant Award UI-37099-21-55-A-54 Grant Award UI-37257-22-55-A-54Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Workforce West Virginia?s (WWV?s) does not perform periodic documented reviews of administrator access changes to the Automated Benefit Payment System (ABPS) or the Unemployment Compensation Tax applications (UC Tax). A user access review is performed periodically for ABPS and UC Tax, however the review is not documented. WWV does not complete documented periodic user access reviews for the Pandemic Unemployment Assistance (PUA) application. Due to a software change, WWV was unable to provide documentation to determine if terminated employees were communicated timely to the West Virginia Office of Technology (WVOT) to remove access or within the organization to remove access to ABPS, UC Tax, and PUA. Complementary user entity controls defined in the Service Organization Controls (SOC) report from Geographic Solutions, Inc. are not in place at WWV. WWV has not performed periodic disaster recovery testing for WWV owned applications. Questioned Costs: N/A Context: Total federal disbursements for the Unemployment Insurance (UI) program were $307,154,978 for the year ended June 30, 2022. Cause: The internal controls over the information technology processes were not adequately designed or implemented. Effect: Unauthorized access to critical information systems may occur and not be detected or resolved in a timely manner causing WWV to be in noncompliance. Recommendation: WWV should implement policies and procedures that include monitoring the information systems and systems controls reports. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?009 SPECIAL TESTS AND PROVISION ? UI PROGRAM INTEGRITY - OVERPAYMENTS (Repeat of Prior Year Findings 2021?007 and 2020?004) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Labor Unemployment Insurance (UI) 17.225 Grant Award UI-35683-21-55-A-54 Grant Award UI-37314-22-55-A-54 Grant Award UI-34749-20-55-A-54 Grant Award UI-35978-21-60-A-54 Grant Award UI-37099-21-55-A-54 Grant Award UI-37257-22-55-A-54Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During fiscal year 2022, the Workforce West Virginia (WWV) overpaid unemployment claims out of funds from the Unemployment Program and the Pandemic Unemployment Assistance Program (PUA). PUA is federal funding provided through the CARES Act to pay unemployment claims for self-employment individuals and independent contractors. Questioned Costs: N/A Context: Total federal disbursements for the Unemployment Insurance (UI) program were $307,154,978 for the year ended June 30, 2022. For three of the 60 overpayments, incomplete documentation did not indicate overpayment classification. For 10 of the 60 overpayments, documentation required by WWV?s policies could not be provided. Cause: WWV?s normal control procedures require proper documentation to be complete for the deputy?s review and approval to complete an overpayment determination and prior to notification to the claimant. However, WWV did not follow policy in retaining required documentation to support deputy decisions for overpayments. Effect: WWV is not following policies and procedures established to identify overpayments and classify them in a manner that allows the state to take appropriate follow-up actions. Recommendation: WWV should enforce appropriate procedures to ensure documentation of review and approval and required forms with deputy decisions is maintained for each overpayment. procedures. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?011 SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS (Repeat of Prior Year Findings 2021?015, 2020?014, and 2019?018) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if - (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition: In six of 10 instances in internal control testing at West Virginia State University (WVSU), we noted that the internal control was not sufficiently documented or not functioning effectively. We also noted inadequate documentation of internal controls at Pierpont Community College (PCTC), Bluefield State University (BSU), New River Community and Technical College (NRCTC), and West Liberty University (WLU). Additionally, for BSU, PCTC, and NRCTC, it was noted that certain amounts to be returned were calculated incorrectly, were not returned timely, or were not calculated and returned at all. Questioned Costs: $11,937 ? BSU; $1,001 ? NRCTC; and $7,530 known questioned cost plus unknown questioned costs for calculations not performed by management for all unofficial withdrawals ? PCTC Context: Total Student Financial Assistance Cluster expenditures for the year ended June 30, 2022, were $480,090,562. The total Student Financial Assistance Cluster expenditures for the year end June 30, 2022, for WVSU, PCTC, BSU, NRCTC, and WLU were $11,188,523, $4,888,594, $7,984,211, $3,423,043, and $15,701,217, respectively. Cause: The institutions do not have adequate internal controls in place over the return of Title IV funds to prevent non-compliance. Effect: The institutions may not be returning the correct amount of federal student financial assistance required or the funds are not returned within the required time frame to the United States Department of Education. Recommendation: Management should implement internal controls to ensure that the correct amount of federal student financial assistance is returned and returned within the required time frame. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?012 SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING (Repeat of Prior Year Findings 2021?016, 2020?015, 2019?019, 2018?012, 2017?006, 2016?008, 2015?015, 2014?011, 2013?028, 2012?43, 2012?47, 2012?49, and 2011?22) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 685.309(b) requires that institutions must ?(1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: In our compliance testing, Fairmont State University (FSU) did not certify the status update within the 60-day requirement. For four of the five internal control instances tested for Blue Ridge Community and Technical College (BRCTC), adequate support for the internal control was not retained. For two of the five internal control instances tested for Pierpont Community and Technical College (PCTC), adequate support for the internal control was not retained. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Further, Marshall University did not submit summer enrollment files to the National Student Clearinghouse. Questioned Costs: N/A Context: Total Direct Loan and Pell expenditures for the SFA cluster in total were $440,969105 for the year ended June 30, 2022. Total Direct Loan and Pell expenditures for FSU, BRCTC, PCTC, WVSU and Marshall University were $17,854,722, $5,105,071, $4,772,684, $10,699,711, and $89,405,192, respectively. Cause: The institutions did not have adequate internal controls in place surrounding the enrollment reporting process. Effect: The institutions may not promptly notify the National Student Loan Data System (NSLDS) of changes in student status in an accurate manner; thus, inaccurate information is reported to the NSLDS. Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. As institutions are responsible for timely reporting whether they report directly or via a third-party servicer, we recommend that the institutions implement a review process to ensure they are promptly notifying the U.S. Department of Education and NSLDS of changes in a student?s status in a timely and accurate manner. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?013 FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE (Repeat of Prior Year Finding 2021?019) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2021, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year ended July 1, 2020 - June 30, 2021, and the Application to Participate for the 2022-2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition: Multiple key line items reported on the June 30, 2022, FISAP Part II for Fairmont State University (FSU), West Virginia State University (WVSU), and the West Virginia School of Osteopathic Medicine (WVSOM) did not reconcile to supporting documentation. WVSU also had key line items in Part IV and V that did not reconcile to supporting documentation. Questioned Costs: Unknown Context: Total Student Financial Assistance Cluster expenditures for FSU, WVSU, and WVSOM were $18,146,824, $11,188,523, and $42,755,731, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: The review process was not designed precise enough to detect inaccurate amounts reported on the FISAP prior to submission to the United States Department of Education. Effect: The United States Department of Education uses the information in the FISAP to determine the amount of funds the institution will receive for each campus-based program. The institution must submit accurate data. If not, the institution might not receive all the funds to which the institution is entitled or might be required to return funds that the institution was not entitled to receive. Recommendation: We recommend that FSU, WVSU, and WVSOM implement more effective policies, procedures, and more precise internal controls surrounding the review of the FISAP to ensure the report is properly reviewed and information reported to the Department is accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?014 FINANCIAL REPORTING (Repeat of Prior Year Findings 2021?020, 2020?011, and 2019?015) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: In our control testing, Pierpont Community and Technical College (PCTC) could not provide adequate documentation of controls in place over Pell COD reconciliations to ensure the data reported is complete, accurate, and prepared in accordance with the required instructions. West Virginia State University (WVSU) has no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loans and Pell, expenditures for PCTC and WVSU were $4,772,684 and $10,699,711 for the year ended June 30, 2022. The total expenditures for Direct Loans, Pell, TEACH, and IASG for the year ended June 30, 2022 was $441,445,850. Cause: PCTC?s policies and procedures do not require adequate documentation be maintained to demonstrate that controls are operating effectively. WVSU had written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The U.S. Department of Education could receive incorrect Pell or Direct Loan payment data. Recommendation: We recommend that PCTC implement more effective policies and procedures surrounding the review and approval of the Pell payment data prior to submission. We recommend that WVSU management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?015 SPECIAL TESTS AND PROVISIONS ? VERIFICATION (Repeat of Prior Year Findings 2021?014, 2020?012, and 2019?016) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The 2022 Federal Compliance Supplement requires that ?a menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. The institution shall also require applicants to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate and provide an accurate code for the individual?s verification status in the Common Origination and Disbursement (COD) system (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4).? Condition: Bluefield State University (BSU), Fairmont State university (FSU), and Pierpont Community and Technical College (PCTC) did not have adequate internal controls in place surrounding the verification compliance requirement. During our testing, we noted for the samples selected that there was no documentation that a review was performed over the verification files. Additionally, PCTC could not locate documentation supporting the completion of the verification for one student selected. Questioned Cost: $16,573 ? PCTC Context: Total Student Financial Assistance Cluster expenditures for BSU, FSU, and PCTC were $7,984,211, $18,146,824, and $4,888,594, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: BSU, FSU, and PCTC did not have adequate internal controls in place to ensure that verification changes identified were processed and submitted to the U.S. Department of Education. Effect: Students receiving federal aid could receive the incorrect amount of federal student financial assistance. Recommendation: Management should develop and update internal controls to ensure that changes identified during the verification process are submitted to the U.S. Department of Education. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?016 SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION (Repeat of Prior Year Findings 2021?013, 2020?016, 2019?020, 2018?013, 2017?007, and 2016?006) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 685.300(b)(5) states that schools must agree to ?On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary.? Condition: For our control testing of the Direct Loan School Account Statement (SAS) reconciliation requirements at Pierpont Community and Technical College (PCTC), there was no identifiable control. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loan expenditures for the SFA cluster in total were $350,719,890, for the year ended June 30, 2022. Total Direct Loan expenditures for PCTC and WVSU were $2,582,514 and $11,188,523, respectively for the year ended June 30, 2022. Cause: Written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The absence of proper reviews over the reconciliations could cause the institution?s financial records for Direct Loan expenditures to be improperly stated. Recommendation: We recommend that management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?017 SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY (Repeat of Prior Year Findings 2021?018, 2020?018, and 2019?022) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 16 CFR 314.4 (b) requires institutions to base their information security programs on a risk assessment that ?identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks.? Condition: Fairmont State University (FSU) and Pierpont Community and Technical College (PCTC) did not perform an adequate risk assessment that covered the entire fiscal year. It is to be noted that FSU performed the required risk assessment June 1, 2022 and documented safeguards for the risks identified which covered one month and PCTC performed the required risk assessment in December 2021 and documented safeguards for the risks identified which covered six months. Further, the institutions identified above do not have internal controls in place surrounding the Gramm-Leach-Bliley Act requirements regarding student information security. Questioned Costs: N/A Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Cause: Institutions do not have policies and procedures, including internal controls, addressing the requirements of the Gramm-Leach-Bliley Act regarding student information security. Effect: The absence of policies and procedures could result in the loss or improper storage of student account information. Recommendation: We recommend that management implement policies and procedures, including internal controls, to ensure that they are in compliance with the Gramm-Leach-Bliley Act regarding student information security. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?018 SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS (Repeat of Prior Year Findings 2021?012, 2020?013, 2019?017, and 2018?011) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 668.165(a)(2), requires that, ?Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of? (i) The anticipated date and amount of the disbursement; (ii) The student?s or parent?s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing.? Condition: For one disbursement notification selected for testing at Pierpont Community and Technical College (PCTC), the disbursement date on the notification did not match the actual date of disbursement. Questioned Costs: $3,711 ? PCTC ? Assistance Listing #84.268 Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Total SFA cluster expenditures for PCTC were $4,888,594 for the year ended June 30, 2022. Cause: Internal controls and policies and procedures related to the institution?s disbursement notifications were not effectively implemented. Effect: Without proper notification of a loan or grant disbursement, a student could lose the opportunity to cancel the loan or grant within the required timeframe. Recommendation: We recommend that the institution implement more effective internal controls and policies and procedures to ensure that all information required as part of the disbursement notifications sent to students is accurate. Further, documentation supporting the disbursement and related notification should be maintained as evidence of the institution?s compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?011 SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS (Repeat of Prior Year Findings 2021?015, 2020?014, and 2019?018) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if - (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition: In six of 10 instances in internal control testing at West Virginia State University (WVSU), we noted that the internal control was not sufficiently documented or not functioning effectively. We also noted inadequate documentation of internal controls at Pierpont Community College (PCTC), Bluefield State University (BSU), New River Community and Technical College (NRCTC), and West Liberty University (WLU). Additionally, for BSU, PCTC, and NRCTC, it was noted that certain amounts to be returned were calculated incorrectly, were not returned timely, or were not calculated and returned at all. Questioned Costs: $11,937 ? BSU; $1,001 ? NRCTC; and $7,530 known questioned cost plus unknown questioned costs for calculations not performed by management for all unofficial withdrawals ? PCTC Context: Total Student Financial Assistance Cluster expenditures for the year ended June 30, 2022, were $480,090,562. The total Student Financial Assistance Cluster expenditures for the year end June 30, 2022, for WVSU, PCTC, BSU, NRCTC, and WLU were $11,188,523, $4,888,594, $7,984,211, $3,423,043, and $15,701,217, respectively. Cause: The institutions do not have adequate internal controls in place over the return of Title IV funds to prevent non-compliance. Effect: The institutions may not be returning the correct amount of federal student financial assistance required or the funds are not returned within the required time frame to the United States Department of Education. Recommendation: Management should implement internal controls to ensure that the correct amount of federal student financial assistance is returned and returned within the required time frame. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?012 SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING (Repeat of Prior Year Findings 2021?016, 2020?015, 2019?019, 2018?012, 2017?006, 2016?008, 2015?015, 2014?011, 2013?028, 2012?43, 2012?47, 2012?49, and 2011?22) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 685.309(b) requires that institutions must ?(1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: In our compliance testing, Fairmont State University (FSU) did not certify the status update within the 60-day requirement. For four of the five internal control instances tested for Blue Ridge Community and Technical College (BRCTC), adequate support for the internal control was not retained. For two of the five internal control instances tested for Pierpont Community and Technical College (PCTC), adequate support for the internal control was not retained. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Further, Marshall University did not submit summer enrollment files to the National Student Clearinghouse. Questioned Costs: N/A Context: Total Direct Loan and Pell expenditures for the SFA cluster in total were $440,969105 for the year ended June 30, 2022. Total Direct Loan and Pell expenditures for FSU, BRCTC, PCTC, WVSU and Marshall University were $17,854,722, $5,105,071, $4,772,684, $10,699,711, and $89,405,192, respectively. Cause: The institutions did not have adequate internal controls in place surrounding the enrollment reporting process. Effect: The institutions may not promptly notify the National Student Loan Data System (NSLDS) of changes in student status in an accurate manner; thus, inaccurate information is reported to the NSLDS. Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. As institutions are responsible for timely reporting whether they report directly or via a third-party servicer, we recommend that the institutions implement a review process to ensure they are promptly notifying the U.S. Department of Education and NSLDS of changes in a student?s status in a timely and accurate manner. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?013 FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE (Repeat of Prior Year Finding 2021?019) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2021, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year ended July 1, 2020 - June 30, 2021, and the Application to Participate for the 2022-2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition: Multiple key line items reported on the June 30, 2022, FISAP Part II for Fairmont State University (FSU), West Virginia State University (WVSU), and the West Virginia School of Osteopathic Medicine (WVSOM) did not reconcile to supporting documentation. WVSU also had key line items in Part IV and V that did not reconcile to supporting documentation. Questioned Costs: Unknown Context: Total Student Financial Assistance Cluster expenditures for FSU, WVSU, and WVSOM were $18,146,824, $11,188,523, and $42,755,731, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: The review process was not designed precise enough to detect inaccurate amounts reported on the FISAP prior to submission to the United States Department of Education. Effect: The United States Department of Education uses the information in the FISAP to determine the amount of funds the institution will receive for each campus-based program. The institution must submit accurate data. If not, the institution might not receive all the funds to which the institution is entitled or might be required to return funds that the institution was not entitled to receive. Recommendation: We recommend that FSU, WVSU, and WVSOM implement more effective policies, procedures, and more precise internal controls surrounding the review of the FISAP to ensure the report is properly reviewed and information reported to the Department is accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?014 FINANCIAL REPORTING (Repeat of Prior Year Findings 2021?020, 2020?011, and 2019?015) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: In our control testing, Pierpont Community and Technical College (PCTC) could not provide adequate documentation of controls in place over Pell COD reconciliations to ensure the data reported is complete, accurate, and prepared in accordance with the required instructions. West Virginia State University (WVSU) has no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loans and Pell, expenditures for PCTC and WVSU were $4,772,684 and $10,699,711 for the year ended June 30, 2022. The total expenditures for Direct Loans, Pell, TEACH, and IASG for the year ended June 30, 2022 was $441,445,850. Cause: PCTC?s policies and procedures do not require adequate documentation be maintained to demonstrate that controls are operating effectively. WVSU had written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The U.S. Department of Education could receive incorrect Pell or Direct Loan payment data. Recommendation: We recommend that PCTC implement more effective policies and procedures surrounding the review and approval of the Pell payment data prior to submission. We recommend that WVSU management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?015 SPECIAL TESTS AND PROVISIONS ? VERIFICATION (Repeat of Prior Year Findings 2021?014, 2020?012, and 2019?016) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The 2022 Federal Compliance Supplement requires that ?a menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. The institution shall also require applicants to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate and provide an accurate code for the individual?s verification status in the Common Origination and Disbursement (COD) system (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4).? Condition: Bluefield State University (BSU), Fairmont State university (FSU), and Pierpont Community and Technical College (PCTC) did not have adequate internal controls in place surrounding the verification compliance requirement. During our testing, we noted for the samples selected that there was no documentation that a review was performed over the verification files. Additionally, PCTC could not locate documentation supporting the completion of the verification for one student selected. Questioned Cost: $16,573 ? PCTC Context: Total Student Financial Assistance Cluster expenditures for BSU, FSU, and PCTC were $7,984,211, $18,146,824, and $4,888,594, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: BSU, FSU, and PCTC did not have adequate internal controls in place to ensure that verification changes identified were processed and submitted to the U.S. Department of Education. Effect: Students receiving federal aid could receive the incorrect amount of federal student financial assistance. Recommendation: Management should develop and update internal controls to ensure that changes identified during the verification process are submitted to the U.S. Department of Education. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?016 SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION (Repeat of Prior Year Findings 2021?013, 2020?016, 2019?020, 2018?013, 2017?007, and 2016?006) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 685.300(b)(5) states that schools must agree to ?On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary.? Condition: For our control testing of the Direct Loan School Account Statement (SAS) reconciliation requirements at Pierpont Community and Technical College (PCTC), there was no identifiable control. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loan expenditures for the SFA cluster in total were $350,719,890, for the year ended June 30, 2022. Total Direct Loan expenditures for PCTC and WVSU were $2,582,514 and $11,188,523, respectively for the year ended June 30, 2022. Cause: Written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The absence of proper reviews over the reconciliations could cause the institution?s financial records for Direct Loan expenditures to be improperly stated. Recommendation: We recommend that management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?017 SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY (Repeat of Prior Year Findings 2021?018, 2020?018, and 2019?022) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 16 CFR 314.4 (b) requires institutions to base their information security programs on a risk assessment that ?identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks.? Condition: Fairmont State University (FSU) and Pierpont Community and Technical College (PCTC) did not perform an adequate risk assessment that covered the entire fiscal year. It is to be noted that FSU performed the required risk assessment June 1, 2022 and documented safeguards for the risks identified which covered one month and PCTC performed the required risk assessment in December 2021 and documented safeguards for the risks identified which covered six months. Further, the institutions identified above do not have internal controls in place surrounding the Gramm-Leach-Bliley Act requirements regarding student information security. Questioned Costs: N/A Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Cause: Institutions do not have policies and procedures, including internal controls, addressing the requirements of the Gramm-Leach-Bliley Act regarding student information security. Effect: The absence of policies and procedures could result in the loss or improper storage of student account information. Recommendation: We recommend that management implement policies and procedures, including internal controls, to ensure that they are in compliance with the Gramm-Leach-Bliley Act regarding student information security. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?018 SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS (Repeat of Prior Year Findings 2021?012, 2020?013, 2019?017, and 2018?011) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 668.165(a)(2), requires that, ?Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of? (i) The anticipated date and amount of the disbursement; (ii) The student?s or parent?s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing.? Condition: For one disbursement notification selected for testing at Pierpont Community and Technical College (PCTC), the disbursement date on the notification did not match the actual date of disbursement. Questioned Costs: $3,711 ? PCTC ? Assistance Listing #84.268 Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Total SFA cluster expenditures for PCTC were $4,888,594 for the year ended June 30, 2022. Cause: Internal controls and policies and procedures related to the institution?s disbursement notifications were not effectively implemented. Effect: Without proper notification of a loan or grant disbursement, a student could lose the opportunity to cancel the loan or grant within the required timeframe. Recommendation: We recommend that the institution implement more effective internal controls and policies and procedures to ensure that all information required as part of the disbursement notifications sent to students is accurate. Further, documentation supporting the disbursement and related notification should be maintained as evidence of the institution?s compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?011 SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS (Repeat of Prior Year Findings 2021?015, 2020?014, and 2019?018) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if - (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition: In six of 10 instances in internal control testing at West Virginia State University (WVSU), we noted that the internal control was not sufficiently documented or not functioning effectively. We also noted inadequate documentation of internal controls at Pierpont Community College (PCTC), Bluefield State University (BSU), New River Community and Technical College (NRCTC), and West Liberty University (WLU). Additionally, for BSU, PCTC, and NRCTC, it was noted that certain amounts to be returned were calculated incorrectly, were not returned timely, or were not calculated and returned at all. Questioned Costs: $11,937 ? BSU; $1,001 ? NRCTC; and $7,530 known questioned cost plus unknown questioned costs for calculations not performed by management for all unofficial withdrawals ? PCTC Context: Total Student Financial Assistance Cluster expenditures for the year ended June 30, 2022, were $480,090,562. The total Student Financial Assistance Cluster expenditures for the year end June 30, 2022, for WVSU, PCTC, BSU, NRCTC, and WLU were $11,188,523, $4,888,594, $7,984,211, $3,423,043, and $15,701,217, respectively. Cause: The institutions do not have adequate internal controls in place over the return of Title IV funds to prevent non-compliance. Effect: The institutions may not be returning the correct amount of federal student financial assistance required or the funds are not returned within the required time frame to the United States Department of Education. Recommendation: Management should implement internal controls to ensure that the correct amount of federal student financial assistance is returned and returned within the required time frame. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?012 SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING (Repeat of Prior Year Findings 2021?016, 2020?015, 2019?019, 2018?012, 2017?006, 2016?008, 2015?015, 2014?011, 2013?028, 2012?43, 2012?47, 2012?49, and 2011?22) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 685.309(b) requires that institutions must ?(1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: In our compliance testing, Fairmont State University (FSU) did not certify the status update within the 60-day requirement. For four of the five internal control instances tested for Blue Ridge Community and Technical College (BRCTC), adequate support for the internal control was not retained. For two of the five internal control instances tested for Pierpont Community and Technical College (PCTC), adequate support for the internal control was not retained. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Further, Marshall University did not submit summer enrollment files to the National Student Clearinghouse. Questioned Costs: N/A Context: Total Direct Loan and Pell expenditures for the SFA cluster in total were $440,969105 for the year ended June 30, 2022. Total Direct Loan and Pell expenditures for FSU, BRCTC, PCTC, WVSU and Marshall University were $17,854,722, $5,105,071, $4,772,684, $10,699,711, and $89,405,192, respectively. Cause: The institutions did not have adequate internal controls in place surrounding the enrollment reporting process. Effect: The institutions may not promptly notify the National Student Loan Data System (NSLDS) of changes in student status in an accurate manner; thus, inaccurate information is reported to the NSLDS. Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. As institutions are responsible for timely reporting whether they report directly or via a third-party servicer, we recommend that the institutions implement a review process to ensure they are promptly notifying the U.S. Department of Education and NSLDS of changes in a student?s status in a timely and accurate manner. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?013 FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE (Repeat of Prior Year Finding 2021?019) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2021, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year ended July 1, 2020 - June 30, 2021, and the Application to Participate for the 2022-2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition: Multiple key line items reported on the June 30, 2022, FISAP Part II for Fairmont State University (FSU), West Virginia State University (WVSU), and the West Virginia School of Osteopathic Medicine (WVSOM) did not reconcile to supporting documentation. WVSU also had key line items in Part IV and V that did not reconcile to supporting documentation. Questioned Costs: Unknown Context: Total Student Financial Assistance Cluster expenditures for FSU, WVSU, and WVSOM were $18,146,824, $11,188,523, and $42,755,731, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: The review process was not designed precise enough to detect inaccurate amounts reported on the FISAP prior to submission to the United States Department of Education. Effect: The United States Department of Education uses the information in the FISAP to determine the amount of funds the institution will receive for each campus-based program. The institution must submit accurate data. If not, the institution might not receive all the funds to which the institution is entitled or might be required to return funds that the institution was not entitled to receive. Recommendation: We recommend that FSU, WVSU, and WVSOM implement more effective policies, procedures, and more precise internal controls surrounding the review of the FISAP to ensure the report is properly reviewed and information reported to the Department is accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?014 FINANCIAL REPORTING (Repeat of Prior Year Findings 2021?020, 2020?011, and 2019?015) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: In our control testing, Pierpont Community and Technical College (PCTC) could not provide adequate documentation of controls in place over Pell COD reconciliations to ensure the data reported is complete, accurate, and prepared in accordance with the required instructions. West Virginia State University (WVSU) has no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loans and Pell, expenditures for PCTC and WVSU were $4,772,684 and $10,699,711 for the year ended June 30, 2022. The total expenditures for Direct Loans, Pell, TEACH, and IASG for the year ended June 30, 2022 was $441,445,850. Cause: PCTC?s policies and procedures do not require adequate documentation be maintained to demonstrate that controls are operating effectively. WVSU had written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The U.S. Department of Education could receive incorrect Pell or Direct Loan payment data. Recommendation: We recommend that PCTC implement more effective policies and procedures surrounding the review and approval of the Pell payment data prior to submission. We recommend that WVSU management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?015 SPECIAL TESTS AND PROVISIONS ? VERIFICATION (Repeat of Prior Year Findings 2021?014, 2020?012, and 2019?016) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The 2022 Federal Compliance Supplement requires that ?a menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. The institution shall also require applicants to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate and provide an accurate code for the individual?s verification status in the Common Origination and Disbursement (COD) system (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4).? Condition: Bluefield State University (BSU), Fairmont State university (FSU), and Pierpont Community and Technical College (PCTC) did not have adequate internal controls in place surrounding the verification compliance requirement. During our testing, we noted for the samples selected that there was no documentation that a review was performed over the verification files. Additionally, PCTC could not locate documentation supporting the completion of the verification for one student selected. Questioned Cost: $16,573 ? PCTC Context: Total Student Financial Assistance Cluster expenditures for BSU, FSU, and PCTC were $7,984,211, $18,146,824, and $4,888,594, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: BSU, FSU, and PCTC did not have adequate internal controls in place to ensure that verification changes identified were processed and submitted to the U.S. Department of Education. Effect: Students receiving federal aid could receive the incorrect amount of federal student financial assistance. Recommendation: Management should develop and update internal controls to ensure that changes identified during the verification process are submitted to the U.S. Department of Education. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?016 SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION (Repeat of Prior Year Findings 2021?013, 2020?016, 2019?020, 2018?013, 2017?007, and 2016?006) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 685.300(b)(5) states that schools must agree to ?On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary.? Condition: For our control testing of the Direct Loan School Account Statement (SAS) reconciliation requirements at Pierpont Community and Technical College (PCTC), there was no identifiable control. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loan expenditures for the SFA cluster in total were $350,719,890, for the year ended June 30, 2022. Total Direct Loan expenditures for PCTC and WVSU were $2,582,514 and $11,188,523, respectively for the year ended June 30, 2022. Cause: Written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The absence of proper reviews over the reconciliations could cause the institution?s financial records for Direct Loan expenditures to be improperly stated. Recommendation: We recommend that management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?017 SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY (Repeat of Prior Year Findings 2021?018, 2020?018, and 2019?022) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 16 CFR 314.4 (b) requires institutions to base their information security programs on a risk assessment that ?identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks.? Condition: Fairmont State University (FSU) and Pierpont Community and Technical College (PCTC) did not perform an adequate risk assessment that covered the entire fiscal year. It is to be noted that FSU performed the required risk assessment June 1, 2022 and documented safeguards for the risks identified which covered one month and PCTC performed the required risk assessment in December 2021 and documented safeguards for the risks identified which covered six months. Further, the institutions identified above do not have internal controls in place surrounding the Gramm-Leach-Bliley Act requirements regarding student information security. Questioned Costs: N/A Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Cause: Institutions do not have policies and procedures, including internal controls, addressing the requirements of the Gramm-Leach-Bliley Act regarding student information security. Effect: The absence of policies and procedures could result in the loss or improper storage of student account information. Recommendation: We recommend that management implement policies and procedures, including internal controls, to ensure that they are in compliance with the Gramm-Leach-Bliley Act regarding student information security. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?018 SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS (Repeat of Prior Year Findings 2021?012, 2020?013, 2019?017, and 2018?011) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 668.165(a)(2), requires that, ?Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of? (i) The anticipated date and amount of the disbursement; (ii) The student?s or parent?s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing.? Condition: For one disbursement notification selected for testing at Pierpont Community and Technical College (PCTC), the disbursement date on the notification did not match the actual date of disbursement. Questioned Costs: $3,711 ? PCTC ? Assistance Listing #84.268 Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Total SFA cluster expenditures for PCTC were $4,888,594 for the year ended June 30, 2022. Cause: Internal controls and policies and procedures related to the institution?s disbursement notifications were not effectively implemented. Effect: Without proper notification of a loan or grant disbursement, a student could lose the opportunity to cancel the loan or grant within the required timeframe. Recommendation: We recommend that the institution implement more effective internal controls and policies and procedures to ensure that all information required as part of the disbursement notifications sent to students is accurate. Further, documentation supporting the disbursement and related notification should be maintained as evidence of the institution?s compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?011 SPECIAL TESTS AND PROVISIONS ? RETURN OF TITLE IV FUNDS (Repeat of Prior Year Findings 2021?015, 2020?014, and 2019?018) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 668.173(b) requires timely return of title IV, HEA program funds. In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower?s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if - (i) The institution?s records show that the check was issued more than 45 days after the date the institution determined that the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition: In six of 10 instances in internal control testing at West Virginia State University (WVSU), we noted that the internal control was not sufficiently documented or not functioning effectively. We also noted inadequate documentation of internal controls at Pierpont Community College (PCTC), Bluefield State University (BSU), New River Community and Technical College (NRCTC), and West Liberty University (WLU). Additionally, for BSU, PCTC, and NRCTC, it was noted that certain amounts to be returned were calculated incorrectly, were not returned timely, or were not calculated and returned at all. Questioned Costs: $11,937 ? BSU; $1,001 ? NRCTC; and $7,530 known questioned cost plus unknown questioned costs for calculations not performed by management for all unofficial withdrawals ? PCTC Context: Total Student Financial Assistance Cluster expenditures for the year ended June 30, 2022, were $480,090,562. The total Student Financial Assistance Cluster expenditures for the year end June 30, 2022, for WVSU, PCTC, BSU, NRCTC, and WLU were $11,188,523, $4,888,594, $7,984,211, $3,423,043, and $15,701,217, respectively. Cause: The institutions do not have adequate internal controls in place over the return of Title IV funds to prevent non-compliance. Effect: The institutions may not be returning the correct amount of federal student financial assistance required or the funds are not returned within the required time frame to the United States Department of Education. Recommendation: Management should implement internal controls to ensure that the correct amount of federal student financial assistance is returned and returned within the required time frame. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?012 SPECIAL TESTS AND PROVISIONS ? ENROLLMENT REPORTING (Repeat of Prior Year Findings 2021?016, 2020?015, 2019?019, 2018?012, 2017?006, 2016?008, 2015?015, 2014?011, 2013?028, 2012?43, 2012?47, 2012?49, and 2011?22) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR section 685.309(b) requires that institutions must ?(1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: In our compliance testing, Fairmont State University (FSU) did not certify the status update within the 60-day requirement. For four of the five internal control instances tested for Blue Ridge Community and Technical College (BRCTC), adequate support for the internal control was not retained. For two of the five internal control instances tested for Pierpont Community and Technical College (PCTC), adequate support for the internal control was not retained. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Further, Marshall University did not submit summer enrollment files to the National Student Clearinghouse. Questioned Costs: N/A Context: Total Direct Loan and Pell expenditures for the SFA cluster in total were $440,969105 for the year ended June 30, 2022. Total Direct Loan and Pell expenditures for FSU, BRCTC, PCTC, WVSU and Marshall University were $17,854,722, $5,105,071, $4,772,684, $10,699,711, and $89,405,192, respectively. Cause: The institutions did not have adequate internal controls in place surrounding the enrollment reporting process. Effect: The institutions may not promptly notify the National Student Loan Data System (NSLDS) of changes in student status in an accurate manner; thus, inaccurate information is reported to the NSLDS. Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. As institutions are responsible for timely reporting whether they report directly or via a third-party servicer, we recommend that the institutions implement a review process to ensure they are promptly notifying the U.S. Department of Education and NSLDS of changes in a student?s status in a timely and accurate manner. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?013 FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE (Repeat of Prior Year Finding 2021?019) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) ? This electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2021, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year ended July 1, 2020 - June 30, 2021, and the Application to Participate for the 2022-2023 award year (FWS, FSEOG 34 CFR 673.3; Fiscal Operations Report and Application to Participate Instructions). Condition: Multiple key line items reported on the June 30, 2022, FISAP Part II for Fairmont State University (FSU), West Virginia State University (WVSU), and the West Virginia School of Osteopathic Medicine (WVSOM) did not reconcile to supporting documentation. WVSU also had key line items in Part IV and V that did not reconcile to supporting documentation. Questioned Costs: Unknown Context: Total Student Financial Assistance Cluster expenditures for FSU, WVSU, and WVSOM were $18,146,824, $11,188,523, and $42,755,731, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: The review process was not designed precise enough to detect inaccurate amounts reported on the FISAP prior to submission to the United States Department of Education. Effect: The United States Department of Education uses the information in the FISAP to determine the amount of funds the institution will receive for each campus-based program. The institution must submit accurate data. If not, the institution might not receive all the funds to which the institution is entitled or might be required to return funds that the institution was not entitled to receive. Recommendation: We recommend that FSU, WVSU, and WVSOM implement more effective policies, procedures, and more precise internal controls surrounding the review of the FISAP to ensure the report is properly reviewed and information reported to the Department is accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?014 FINANCIAL REPORTING (Repeat of Prior Year Findings 2021?020, 2020?011, and 2019?015) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: In our control testing, Pierpont Community and Technical College (PCTC) could not provide adequate documentation of controls in place over Pell COD reconciliations to ensure the data reported is complete, accurate, and prepared in accordance with the required instructions. West Virginia State University (WVSU) has no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loans and Pell, expenditures for PCTC and WVSU were $4,772,684 and $10,699,711 for the year ended June 30, 2022. The total expenditures for Direct Loans, Pell, TEACH, and IASG for the year ended June 30, 2022 was $441,445,850. Cause: PCTC?s policies and procedures do not require adequate documentation be maintained to demonstrate that controls are operating effectively. WVSU had written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The U.S. Department of Education could receive incorrect Pell or Direct Loan payment data. Recommendation: We recommend that PCTC implement more effective policies and procedures surrounding the review and approval of the Pell payment data prior to submission. We recommend that WVSU management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?015 SPECIAL TESTS AND PROVISIONS ? VERIFICATION (Repeat of Prior Year Findings 2021?014, 2020?012, and 2019?016) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The 2022 Federal Compliance Supplement requires that ?a menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student?s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. The institution shall also require applicants to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate and provide an accurate code for the individual?s verification status in the Common Origination and Disbursement (COD) system (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4).? Condition: Bluefield State University (BSU), Fairmont State university (FSU), and Pierpont Community and Technical College (PCTC) did not have adequate internal controls in place surrounding the verification compliance requirement. During our testing, we noted for the samples selected that there was no documentation that a review was performed over the verification files. Additionally, PCTC could not locate documentation supporting the completion of the verification for one student selected. Questioned Cost: $16,573 ? PCTC Context: Total Student Financial Assistance Cluster expenditures for BSU, FSU, and PCTC were $7,984,211, $18,146,824, and $4,888,594, respectively, for the year ended June 30, 2022. The total expenditures for the Student Financial Assistance Cluster for the year ended June 30, 2022 were $480,090,562. Cause: BSU, FSU, and PCTC did not have adequate internal controls in place to ensure that verification changes identified were processed and submitted to the U.S. Department of Education. Effect: Students receiving federal aid could receive the incorrect amount of federal student financial assistance. Recommendation: Management should develop and update internal controls to ensure that changes identified during the verification process are submitted to the U.S. Department of Education. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?016 SPECIAL TESTS AND PROVISIONS ? BORROWER DATA TRANSMISSION AND RECONCILIATION (Repeat of Prior Year Findings 2021?013, 2020?016, 2019?020, 2018?013, 2017?007, and 2016?006) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 685.300(b)(5) states that schools must agree to ?On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary.? Condition: For our control testing of the Direct Loan School Account Statement (SAS) reconciliation requirements at Pierpont Community and Technical College (PCTC), there was no identifiable control. At West Virginia State University, there was no identifiable control that could be tested in the fall semester. Questioned Costs: N/A Context: Total Direct Loan expenditures for the SFA cluster in total were $350,719,890, for the year ended June 30, 2022. Total Direct Loan expenditures for PCTC and WVSU were $2,582,514 and $11,188,523, respectively for the year ended June 30, 2022. Cause: Written procedures detailing the process to reconcile loans from Common Origination and Disbursement (COD) records to Banner exist. However, management represented that a formal reconciliation review process has not been successfully implemented. Effect: The absence of proper reviews over the reconciliations could cause the institution?s financial records for Direct Loan expenditures to be improperly stated. Recommendation: We recommend that management implement its existing process that monthly reconciliations are performed and saved, as documented in the institution?s written procedure, including documentation of supervisor review and approval. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?017 SPECIAL TESTS AND PROVISIONS ? GRAMM-LEACH-BLILEY ACT ? STUDENT INFORMATION SECURITY (Repeat of Prior Year Findings 2021?018, 2020?018, and 2019?022) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 16 CFR 314.4 (b) requires institutions to base their information security programs on a risk assessment that ?identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks.? Condition: Fairmont State University (FSU) and Pierpont Community and Technical College (PCTC) did not perform an adequate risk assessment that covered the entire fiscal year. It is to be noted that FSU performed the required risk assessment June 1, 2022 and documented safeguards for the risks identified which covered one month and PCTC performed the required risk assessment in December 2021 and documented safeguards for the risks identified which covered six months. Further, the institutions identified above do not have internal controls in place surrounding the Gramm-Leach-Bliley Act requirements regarding student information security. Questioned Costs: N/A Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Cause: Institutions do not have policies and procedures, including internal controls, addressing the requirements of the Gramm-Leach-Bliley Act regarding student information security. Effect: The absence of policies and procedures could result in the loss or improper storage of student account information. Recommendation: We recommend that management implement policies and procedures, including internal controls, to ensure that they are in compliance with the Gramm-Leach-Bliley Act regarding student information security. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?018 SPECIAL TESTS AND PROVISIONS ? DISBURSEMENTS TO OR ON BEHALF OF STUDENTS (Repeat of Prior Year Findings 2021?012, 2020?013, 2019?017, and 2018?011) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Office of Student Financial Assistance Office of Post-Secondary Education U.S. Department of Health and Human Services Health Resources and Services Administration Student Financial Assistance (SFA) Cluster 84.007/84.033/84.038/84.063/84.268/84.379/ 84.408/93.264/ 93.342/93.364/ 93.925Criteria: 2 CFR 200.303 requires a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 34 CFR 668.165(a)(2), requires that, ?Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of? (i) The anticipated date and amount of the disbursement; (ii) The student?s or parent?s right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing.? Condition: For one disbursement notification selected for testing at Pierpont Community and Technical College (PCTC), the disbursement date on the notification did not match the actual date of disbursement. Questioned Costs: $3,711 ? PCTC ? Assistance Listing #84.268 Context: Total expenditures for the SFA cluster were $480,090,562 for the year ended June 30, 2022. Total SFA cluster expenditures for PCTC were $4,888,594 for the year ended June 30, 2022. Cause: Internal controls and policies and procedures related to the institution?s disbursement notifications were not effectively implemented. Effect: Without proper notification of a loan or grant disbursement, a student could lose the opportunity to cancel the loan or grant within the required timeframe. Recommendation: We recommend that the institution implement more effective internal controls and policies and procedures to ensure that all information required as part of the disbursement notifications sent to students is accurate. Further, documentation supporting the disbursement and related notification should be maintained as evidence of the institution?s compliance with federal requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?019 CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Education Rehabilitation Services?Vocational Rehabilitation Grants to State 84.126 Grant Award H126A200095, H126A210095, H126A220095 Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The West Virginia Division of Rehabilitation Services (WVDRS) did not have evidence of the review control related to cash management. One of the five drawdowns selected for testing did not have Director approval to draw the funds down. Questioned Costs: N/A Context: Total federal expenditures for the Vocational Rehabilitation Grant were $31,508,101 for the year ended June 30, 2022. Cause: WVDRS appears to have policies and procedures in place to review the draws prior to requesting; however, the policies and procedures were not followed for this draw. Effect: WVDRS could have drawn down the incorrect amount of federal funds. Recommendation: We recommend that WVDRS enforce the existing policies and procedures surrounding the review and approval of the cash draws prior to requesting the funds. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.