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?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. 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?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?027 INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE (Repeat of Prior Year Findings 2021?028, 2020?025, 2019?025, 2018?019, 2017?010, 2016?016, 2015?024, 2014?018, 2013?036, 2012?56, 2011?44, and 2010?41) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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 Department of Health & Human Resources (DHHR) has policies and procedures in place surrounding the issuance and removal of sanctions; however, adequate documentation to test and determine that the controls were operating effectively was not consistently maintained or available. Questioned Costs: N/A Context: Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: Internal controls are not operating effectively surrounding the issuance or removal of sanctions against TANF recipients. Effect: Recipient benefits may potentially be reduced or increased in error or without appropriate cause. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its review prior to the issuance or removal of sanctions. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?028 SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM (Repeat of Prior Year Findings 2021?029 and 2020?026) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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). Each state shall participate in the Income Eligibility and Verification System (IEVS) required by Section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data exchanges with other federally assisted benefit programs, request and use income and benefit information when making eligibility determinations and adhere to standardized formats and procedures in exchanging information with other programs and agencies. Specifically, the state is required to request and obtain information as follows (42 USC 1320b-7; 45CFR section 205.55). (a) Wage information from the state Wage Information Collection Agency (SWICA) should be obtained for all applicants at the first opportunity following receipt of the application, and for all recipients on a quarterly basis. (b) Unemployment Compensation (UC) information should be obtained for all applicants at the first opportunity, and in each of the first three months in which the individual is receiving aid. This information should also be obtained in each of the first three months following any recipient-reported loss of employment. If an individual is found to be receiving UC, the information should be requested until benefits are exhausted. (c) All available information from the Social Security Administration (SSA) for all applicants at the first opportunity. (d) Information from the U.S. Citizenship and Immigration Services and any other information from other agencies in the state or in other states that might provide income or other useful information. (e) Unearned income from the Internal Revenue Service (IRS). Condition: During testing of 40 TANF cases subject to IEVS, we noted the following: Control - For 40 of the 40 cases selected for control testing, adequate documentation of review of the data exchanges, and system matches, and review of actions taken by the caseworker when required was not provided. Compliance- For 13 of the 40 cases selected for testing, the recipient did not appear to be receiving WVWorks benefits. The auditor was unable to determine if these cases should have been subject to a data match under TANF. For three of the 40 cases selected for testing, the recipient appeared to be receiving WVworks benefits, and a data match indicating caseworker action required was noted, but no action was completed. Additionally, additional documentation supporting no action required for the match was not available. For the remaining 24 of the 40 cases, the recipient appeared to be receiving WVWorks, a data match occurred, and related worker action was taken, but documentation supporting the action was not available. In addition, the auditor could not determine if specific action items were completed relating to individual exchange types. Questioned Costs: Unknown Context: Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: There are insufficient internal controls in place surrounding the generation and review of populations provided to the auditor, the Income Eligibility and Verification System matches, and the caseworker actions required within the Recipient Automated Payment Information Data System (RAPIDS). Also, insufficient documentation surrounding matches made between the information systems and actions taken after a match is made. Effect: The State of WV may not be coordinating data exchanges with other federally assisted benefit programs as required by the state plan. Recommendation: We recommend that management implement policies and procedures to ensure that information in RAPIDS and populations are complete and accurate. In addition, we also recommend DHHR evaluate their control over the caseworker action requirement within RAPIDS on matches related to the Income Eligibility and Verification System. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?029 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Low-Income Home Energy Assistance 93.568/ COVID-19 93.568 Grant Award G-2201WVLIEA Grant Award G-2201WVLIEI U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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).? Per 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 for the Low-Income Home Energy Assistance (LIHEAP) program, there were certain instances noted whereby the Department of Health and Human Resources (DHHR) reported incorrect amounts for subawards. Therefore, the LIHEAP program was not in compliance with the provisions of 2 CFR 170 Appendix A. Low-Income Home Energy Assistance (LIHEAP) ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the LIHEAP program included 28 subawards that totaled $14,526,625 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $5,827,409 selected for testing. Total federal expenditures for LIHEAP for the fiscal year ended June 30, 2022, were $50,464,421. Subawards for the TANF program from the West Virginia Department of Education included 12 subawards that totaled $4,909,507 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $1,882,492 selected for testing. Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: In regards to the incorrect amounts for subawards, DHHR received the awards directly from the federal awarding agency. DHHR passed through a portion of the awards to other non-federal entities that were also agencies of the State. Those other agencies of the State subsequently passed through a portion of their awards to other non-federal entities that are not agencies of the State. When DHHR passed through the awards to other agencies of the State, DHHR used their standard grant agreement template since those agencies were external to DHHR. From the perspective of DHHR, DHHR is the prime recipient and the other state agencies were first-tier subrecipients. Therefore, when completing the FFATA reports, the DHHR inappropriately entered the other State agencies as the subrecipient/subawardee. Effect: The FFATA reports do not provide an accurate description of the subawardee information. Recommendation: DHHR should consider the State of West Virginia to be the prime recipient. Even if the DHHR passes through a portion of a federal award to other non-federal entities that are agencies of the State, the DHHR should consider those agencies to be part of the prime recipient tier instead of subrecipients. Regardless of the State agency that receives the award directly from the federal awarding agency, the only time a subrecipient relationship exists for the State is when a portion of the award is passed through to a non-federal entity that is not an agency of the State. Accordingly, when DHHR receives and passes through a portion of a federal award to another agency of the State, DHHR should work with the other agency when completing the FFATA reports in an effort to ensure that all subawardee information is complete and accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. 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?027 INTERNAL CONTROLS OVER SPECIAL TESTS AND PROVISIONS ? CHILD SUPPORT NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE (Repeat of Prior Year Findings 2021?028, 2020?025, 2019?025, 2018?019, 2017?010, 2016?016, 2015?024, 2014?018, 2013?036, 2012?56, 2011?44, and 2010?41) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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 Department of Health & Human Resources (DHHR) has policies and procedures in place surrounding the issuance and removal of sanctions; however, adequate documentation to test and determine that the controls were operating effectively was not consistently maintained or available. Questioned Costs: N/A Context: Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: Internal controls are not operating effectively surrounding the issuance or removal of sanctions against TANF recipients. Effect: Recipient benefits may potentially be reduced or increased in error or without appropriate cause. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its review prior to the issuance or removal of sanctions. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?028 SPECIAL TESTS AND PROVISIONS ? INCOME ELIGIBILITY AND VERIFICATION SYSTEM (Repeat of Prior Year Findings 2021?029 and 2020?026) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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). Each state shall participate in the Income Eligibility and Verification System (IEVS) required by Section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data exchanges with other federally assisted benefit programs, request and use income and benefit information when making eligibility determinations and adhere to standardized formats and procedures in exchanging information with other programs and agencies. Specifically, the state is required to request and obtain information as follows (42 USC 1320b-7; 45CFR section 205.55). (a) Wage information from the state Wage Information Collection Agency (SWICA) should be obtained for all applicants at the first opportunity following receipt of the application, and for all recipients on a quarterly basis. (b) Unemployment Compensation (UC) information should be obtained for all applicants at the first opportunity, and in each of the first three months in which the individual is receiving aid. This information should also be obtained in each of the first three months following any recipient-reported loss of employment. If an individual is found to be receiving UC, the information should be requested until benefits are exhausted. (c) All available information from the Social Security Administration (SSA) for all applicants at the first opportunity. (d) Information from the U.S. Citizenship and Immigration Services and any other information from other agencies in the state or in other states that might provide income or other useful information. (e) Unearned income from the Internal Revenue Service (IRS). Condition: During testing of 40 TANF cases subject to IEVS, we noted the following: Control - For 40 of the 40 cases selected for control testing, adequate documentation of review of the data exchanges, and system matches, and review of actions taken by the caseworker when required was not provided. Compliance- For 13 of the 40 cases selected for testing, the recipient did not appear to be receiving WVWorks benefits. The auditor was unable to determine if these cases should have been subject to a data match under TANF. For three of the 40 cases selected for testing, the recipient appeared to be receiving WVworks benefits, and a data match indicating caseworker action required was noted, but no action was completed. Additionally, additional documentation supporting no action required for the match was not available. For the remaining 24 of the 40 cases, the recipient appeared to be receiving WVWorks, a data match occurred, and related worker action was taken, but documentation supporting the action was not available. In addition, the auditor could not determine if specific action items were completed relating to individual exchange types. Questioned Costs: Unknown Context: Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: There are insufficient internal controls in place surrounding the generation and review of populations provided to the auditor, the Income Eligibility and Verification System matches, and the caseworker actions required within the Recipient Automated Payment Information Data System (RAPIDS). Also, insufficient documentation surrounding matches made between the information systems and actions taken after a match is made. Effect: The State of WV may not be coordinating data exchanges with other federally assisted benefit programs as required by the state plan. Recommendation: We recommend that management implement policies and procedures to ensure that information in RAPIDS and populations are complete and accurate. In addition, we also recommend DHHR evaluate their control over the caseworker action requirement within RAPIDS on matches related to the Income Eligibility and Verification System. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?029 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Low-Income Home Energy Assistance 93.568/ COVID-19 93.568 Grant Award G-2201WVLIEA Grant Award G-2201WVLIEI U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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).? Per 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 for the Low-Income Home Energy Assistance (LIHEAP) program, there were certain instances noted whereby the Department of Health and Human Resources (DHHR) reported incorrect amounts for subawards. Therefore, the LIHEAP program was not in compliance with the provisions of 2 CFR 170 Appendix A. Low-Income Home Energy Assistance (LIHEAP) ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the LIHEAP program included 28 subawards that totaled $14,526,625 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $5,827,409 selected for testing. Total federal expenditures for LIHEAP for the fiscal year ended June 30, 2022, were $50,464,421. Subawards for the TANF program from the West Virginia Department of Education included 12 subawards that totaled $4,909,507 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $1,882,492 selected for testing. Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: In regards to the incorrect amounts for subawards, DHHR received the awards directly from the federal awarding agency. DHHR passed through a portion of the awards to other non-federal entities that were also agencies of the State. Those other agencies of the State subsequently passed through a portion of their awards to other non-federal entities that are not agencies of the State. When DHHR passed through the awards to other agencies of the State, DHHR used their standard grant agreement template since those agencies were external to DHHR. From the perspective of DHHR, DHHR is the prime recipient and the other state agencies were first-tier subrecipients. Therefore, when completing the FFATA reports, the DHHR inappropriately entered the other State agencies as the subrecipient/subawardee. Effect: The FFATA reports do not provide an accurate description of the subawardee information. Recommendation: DHHR should consider the State of West Virginia to be the prime recipient. Even if the DHHR passes through a portion of a federal award to other non-federal entities that are agencies of the State, the DHHR should consider those agencies to be part of the prime recipient tier instead of subrecipients. Regardless of the State agency that receives the award directly from the federal awarding agency, the only time a subrecipient relationship exists for the State is when a portion of the award is passed through to a non-federal entity that is not an agency of the State. Accordingly, when DHHR receives and passes through a portion of a federal award to another agency of the State, DHHR should work with the other agency when completing the FFATA reports in an effort to ensure that all subawardee information is complete and accurate. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. 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?029 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Low-Income Home Energy Assistance 93.568/ COVID-19 93.568 Grant Award G-2201WVLIEA Grant Award G-2201WVLIEI U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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).? Per 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 for the Low-Income Home Energy Assistance (LIHEAP) program, there were certain instances noted whereby the Department of Health and Human Resources (DHHR) reported incorrect amounts for subawards. Therefore, the LIHEAP program was not in compliance with the provisions of 2 CFR 170 Appendix A. Low-Income Home Energy Assistance (LIHEAP) ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the LIHEAP program included 28 subawards that totaled $14,526,625 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $5,827,409 selected for testing. Total federal expenditures for LIHEAP for the fiscal year ended June 30, 2022, were $50,464,421. Subawards for the TANF program from the West Virginia Department of Education included 12 subawards that totaled $4,909,507 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $1,882,492 selected for testing. Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: In regards to the incorrect amounts for subawards, DHHR received the awards directly from the federal awarding agency. DHHR passed through a portion of the awards to other non-federal entities that were also agencies of the State. Those other agencies of the State subsequently passed through a portion of their awards to other non-federal entities that are not agencies of the State. When DHHR passed through the awards to other agencies of the State, DHHR used their standard grant agreement template since those agencies were external to DHHR. From the perspective of DHHR, DHHR is the prime recipient and the other state agencies were first-tier subrecipients. Therefore, when completing the FFATA reports, the DHHR inappropriately entered the other State agencies as the subrecipient/subawardee. Effect: The FFATA reports do not provide an accurate description of the subawardee information. Recommendation: DHHR should consider the State of West Virginia to be the prime recipient. Even if the DHHR passes through a portion of a federal award to other non-federal entities that are agencies of the State, the DHHR should consider those agencies to be part of the prime recipient tier instead of subrecipients. Regardless of the State agency that receives the award directly from the federal awarding agency, the only time a subrecipient relationship exists for the State is when a portion of the award is passed through to a non-federal entity that is not an agency of the State. Accordingly, when DHHR receives and passes through a portion of a federal award to another agency of the State, DHHR should work with the other agency when completing the FFATA reports in an effort to ensure that all subawardee information is complete and accurate. 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?029 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Low-Income Home Energy Assistance 93.568/ COVID-19 93.568 Grant Award G-2201WVLIEA Grant Award G-2201WVLIEI U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2022 ? 2022G996115 Grant Award 2021 ? 2021G996115 Grant Award 2021 ? 2021G990228Criteria: 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).? Per 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 for the Low-Income Home Energy Assistance (LIHEAP) program, there were certain instances noted whereby the Department of Health and Human Resources (DHHR) reported incorrect amounts for subawards. Therefore, the LIHEAP program was not in compliance with the provisions of 2 CFR 170 Appendix A. Low-Income Home Energy Assistance (LIHEAP) ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the LIHEAP program included 28 subawards that totaled $14,526,625 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $5,827,409 selected for testing. Total federal expenditures for LIHEAP for the fiscal year ended June 30, 2022, were $50,464,421. Subawards for the TANF program from the West Virginia Department of Education included 12 subawards that totaled $4,909,507 for the year ended June 30, 2022. The five subawards that were reported to the FFATA Subaward Reporting System incorrectly represent the entirety of the $1,882,492 selected for testing. Total federal expenditures for TANF for the fiscal year ended June 30, 2022, were $105,423,491. Cause: In regards to the incorrect amounts for subawards, DHHR received the awards directly from the federal awarding agency. DHHR passed through a portion of the awards to other non-federal entities that were also agencies of the State. Those other agencies of the State subsequently passed through a portion of their awards to other non-federal entities that are not agencies of the State. When DHHR passed through the awards to other agencies of the State, DHHR used their standard grant agreement template since those agencies were external to DHHR. From the perspective of DHHR, DHHR is the prime recipient and the other state agencies were first-tier subrecipients. Therefore, when completing the FFATA reports, the DHHR inappropriately entered the other State agencies as the subrecipient/subawardee. Effect: The FFATA reports do not provide an accurate description of the subawardee information. Recommendation: DHHR should consider the State of West Virginia to be the prime recipient. Even if the DHHR passes through a portion of a federal award to other non-federal entities that are agencies of the State, the DHHR should consider those agencies to be part of the prime recipient tier instead of subrecipients. Regardless of the State agency that receives the award directly from the federal awarding agency, the only time a subrecipient relationship exists for the State is when a portion of the award is passed through to a non-federal entity that is not an agency of the State. Accordingly, when DHHR receives and passes through a portion of a federal award to another agency of the State, DHHR should work with the other agency when completing the FFATA reports in an effort to ensure that all subawardee information is complete and accurate. 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?030 SPECIAL TESTS AND PROVISIONS ? PROVIDER ELIGIBILITY Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021Criteria: 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). 42 CFR section 455 Subpart E requires CHIP providers to be licensed in accordance with federal, state, and local laws and regulations to participate in the CHIP program, be screened and enrolled in CHIP, and make certain required disclosures to the state. Condition: During our testing of 60 cases for provider eligibility for CHIP, we noted one instance where a provider selected not to be a CHIP provider, however, was documented as a CHIP provider. We also noted four providers who chose to be terminated as a CHIP provider, however, were still documented as a CHIP provider. We also noted three providers did not have a letter of approval noting provider number or effective date. We also noted one provider that did not have a current license in the file. Questioned Costs: Unknown Context: The federal expenditures for the CHIP program for the fiscal year ended June 30, 2022, were $75,615,993. Cause: Management indicated that the providers were input incorrectly into the system. The appropriate documentation was not provided for the providers that did not have a letter of approval or current license. Effect: Payments may have been made to ineligible providers. Recommendation: Management should develop an effective corrective action plan to address this matter in a timely manner. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?031 SPECIAL TESTS AND PROVISIONS ? MEDICAL LOSS RATIO (MLR) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Medicaid Cluster 93.775/93.777/ COVID-19 93.777/ 93.778/ ARRA 93.778 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2005WVINCT Grant Award 1905WV5MAP Grant Award 2005WV5ADM Grant Award 2005WVIMPL Grant Award 2005WV5MAP Grant Award 2105WV5MAP Grant Award 2105WV5ADM Grant Award 2105WVIMPL Grant Award 2105WVINCTCriteria: 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). 42 CFR section 438.3(k) requires each MCO, PIHP, and PAHP to submit a report with the data elements specified in 42 CFR 457.1203(e), cross-referencing 42 CFR 438.8 (k) and 438.8. The report should contain the required 13 data elements in the regulation, reflect the correct reporting years, and contain an attestation of accuracy regarding the calculation of the MLR. The state should have a method to indicate when the report(s) are due from plans and should not accept multiple submissions from plans unless the capitation rates are revised retroactively. Condition: During our testing of the MLR reports of the CHIP and Medicaid contracts required to be submitted by Managed Care Organizations (MCOs), it was noted all three of the MCOs submitted MLR reports, however, DHHR had no documentation of their review and approval of the three MLR reports selected for testing. DHHR does not have any PIHPs or PAHPs. Questioned Costs: N/A Context: The federal expenditures for the CHIP program for the fiscal year ended June 30, 2022, were $75,615,993. The federal expenditures for the Medicaid program for the fiscal year ended June 30, 2022, were $ $4,466,291,166. The population subject to testing were the MLR reports of CHIP and Medicaid?s three MCOs. Cause: Management indicated that the review and approval of the MLR reports was not documented and maintained in the files. Effect: The DHHR does not have a documented control over the Medical Loss Ratio special test requirements. The MCOs may be reporting inaccurate data. Recommendation: We recommend that DHHR create a policy and procedure to ensure that documentation of review and approval of the MLR reports is documented and maintained. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?033 SPECIAL TESTS AND PROVISIONS ? MANAGED CARE FINANCIAL AUDIT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Children?s Health Insurance Program (CHIP) 93.767 Grant Award 2005WV5021 Grant Award 2105WV5021 Grant Award 2205WV5021Criteria: 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). 42 CFR section 438.3(m) requires each MCO, PIHP, and PAHP to submit to the state an audited financial report specific to the CHIP contract on an annual basis. The audit must be conducted in accordance with generally accepted accounting principles and generally accepted auditing standards. Condition: During our testing of the audited financial reports of the CHIP contract required to be submitted by Managed Care Organizations (MCOs), it was noted that none of the MCOs submitted audited financial reports. There are three MCOs and all three of the MCOs were selected for testing. DHHR does not have any PIHPs or PAHPs. Questioned Costs: N/A Context: The federal expenditures for the CHIP program for the fiscal year ended June 30, 2022, were $75,615,993. The populations subject to testing were the financial and periodic audits of Medicaid?s three MCOs. Cause: Management indicated that the audited financial statements had not been obtained. Management indicated that they were in the process of implementing procedures around financial reporting for the MCOs. Effect: The DHHR is not in compliance with the Managed Care Financial Audit special test requirements. The MCOs may be reporting inaccurate encounter or financial data. Recommendation: We recommend that DHHR create a policy and procedure to ensure that the financial audits are obtained and documentation of review and approval of the financial audits is maintained. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?038 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 6H79TI081724 Grant Award 5H79TI083313 Grant Award 1H79TI083313-01 Grant Award 3H79TI081724-01W1 Grant Award 1H79TI081724-01 Grant Award 6H79TI083313Criteria: 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 200.305(b)(1) requires that the non-federal entity must ?monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient.? Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During our testing of the State Targeted Response to the Opioid Crisis Grants, the West Virginia Department of Health and Human Resources (DHHR) was unable to provide adequate documentation supporting why the subrecipient drawdowns were approved for payment for three of the 40 drawdowns selected for testing. The supporting documentation for the draw down showed less expenses than the amount that had been drawn down to date on the grants. The supporting documentation also showed the subrecipients appeared to have adequate cash balances on hand at the time of the request. Questioned Costs: $493,423 Context: The total subrecipient drawdowns selected for testing was $3,521,390. The total amount of subrecipient drawdowns for the Opioid STR program during fiscal year 2022 was $38,332,337. Cause: Documentation to support the amount paid to the subrecipient was not retained by DHHR. In addition, supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. Views of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
2022?039 TRANSPARENCY ACT REPORTING Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 6H79TI081724 Grant Award 5H79TI083313 Grant Award 1H79TI083313-01 Grant Award 3H79TI081724-01W1 Grant Award 1H79TI081724-01 Grant Award 6H79TI083313Criteria: 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 one report was not submitted by the State of West Virginia Opioid STR (DHHR) program management within the timeframe designated in 2 CFR 170 Appendix A, and one report had an incorrect subaward amount. ?See Schedule of Findings and Questioned Costs for char/table? Questioned Costs: N/A Context: Subawards for the Opioid STR program included 183 subawards which had payments that totaled $38,332,337 for the year ended June 30, 2022. The federal expenditures for the Opioid STR program for fiscal year ended June 30, 2022, were $42,026,455. Cause: A lack of oversight and adequate review of the FFATA reporting by DHHR management. Effect: DHHR management did not report the necessary FFATA report for Opioid STR first-tier subawards over $30,000 to The FFATA Subaward Reporting System in a timely fashion for one report and for one report, the wrong amount was reported for the subaward. Recommendation: We recommend that DHHR strengthen internal controls and policies and procedure over FFATA reporting to ensure they are in compliance with federal reporting requirements. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?040 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 6H79TI081724 Grant Award 5H79TI083313 Grant Award 1H79TI083313-01 Grant Award 3H79TI081724-01W1Criteria: 2 CFR 200.303 requires that non-Federal entities 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 Division of Corrections and Rehabilitation?s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports all federal assistance. Our review of the Division?s SEFA for fiscal year 2022 identified that total expenditures under the Opioid STR program were overstated by $805,327. Questioned Costs: N/A Context: The total federal expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455. Cause: The internal controls over the SEFA reporting processes were not operating effectively to ensure the SEFA is accurate. Effect: The Division of Corrections and Rehabilitation is not properly reporting their federal expenditures and major programs may not be appropriately identified on a timely basis. Recommendation: We recommend that the Division 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?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. 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?026 INTERNAL CONTROLS OVER CHILD CARE PROVIDER ELIGIBILITY FOR ARP ACT STABILIZATION FUNDS Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Child Care Disaster Relief/Child Care Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care Development Fund (CCDF Cluster) 93.489/93.575/ 93.596/ COVID-19 93.575 Grant Award 2022 ? 2022G999005 Grant Award 2022 ? 2022G996005 Grant Award 2022 ? 2022G999004 Grant Award 2021 ? 2021G996005 Grant Award 2021 ? 2021G999005 Grant Award 2021 ? 2021G999004Criteria: 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 Department of Health & Human Resources (DHHR) has policies and procedures in place surrounding the review and approval of provider certifications in the application for funding and review and approval of verification of eligibility criteria; however, adequate documentation to test and determine that the controls were operating effectively was not available. Questioned Costs: N/A Context: Total federal expenditures for CCDF Cluster for the fiscal year ended June 30, 2022, were $196,326,309. Cause: Internal controls are not operating effectively surrounding the review and approval of provider certifications and verification of eligibility criteria. Effect: Providers who received ARP Act Stabilization funds may not have met the eligibility criteria or made the required certifications. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its review and approval of provider certifications and eligibility criteria. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.
2022?041 INTERNAL CONTROLS OVER SUBRECIPIENT MONITORING (Repeat of Prior Year Finding 2021?039) Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR-State Targeted Response to the Opioid Crisis Grants 93.788 Grant Award 1H79TI081724-01 Grant Award 6H79TI081724-02M004 Grant Award 1H79TI083313-01 Grant Award 6H79TI081724-02M003 Grant Award 6H79TI083313-01M001 Grant Award 6H79TI083313-02M002 Grant Award 5H79TI083313-02 Child Care and Development Fund (CCDF) Cluster 93.575/93.596/ COVID-19 93.575 Grant Award G2101WVCCDF Grant Award G2201WVCCDF Temporary Assistance for Needy Families (TANF) 93.558/ COVID-19 93.558 Grant Award 2021G996115 Grant Award 2022G996115 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/ COVID19 93.323 Grant Award 6 NU50CK000551-01-06 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-02-03 Grant Award 6 NU50CK000551-01-07 Grant Award 6 NU50CK000551-02-04 Grant Award 6 NU50CK000551-01-05 Grant Award 5 NU50CK000551-02-00 Grant Award 6 NU50CK000551-01-00 Grant Award 6 NU50CK000551-01-01 Grant Award 6 NU50CK000551-02-06 Grant Award 6 NU50CK000551-02-08Criteria: 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 internal control testing of subrecipient monitoring, we determined that the documentation regarding the subrecipient risk assessment is not maintained. Therefore, management was unable to provide documentation supporting that the level of monitoring completed for each subrecipient is appropriate based on the risk assessment. Questioned Costs: N/A Context: The federal expenditures and subrecipient expenditures for the State Targeted Response to the Opioid Crisis program for the fiscal year ended June 30, 2022, were $42,026,455 and $35,047,416, respectively. The federal expenditures and subrecipient expenditures for the Child Care and Development Fund (CCDF) Cluster for the fiscal year ended June 30, 2022, were $196,326,309 and $41,166,713, respectively. The federal expenditures and subrecipient expenditures for the Temporary Assistance for Needy Families (TANF) for the fiscal year ended June 30, 2022, were $105,423,491 and $11,542,396, respectively. The federal expenditures and subrecipient expenditures for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) for the fiscal year ended June 30, 2022, were $105,928,082 and $21,044,729, respectively. Cause: There is lack of sufficient documentary evidence to support that the level of monitoring is appropriate and that controls are operating as designed related to subrecipient monitoring. Effect: Subrecipients may not be properly risk assessed; therefore, impacting the type and amount of monitoring that would be performed in the future. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its assessment of and internal controls surrounding the extent of subrecipient monitoring. 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?026 INTERNAL CONTROLS OVER CHILD CARE PROVIDER ELIGIBILITY FOR ARP ACT STABILIZATION FUNDS Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Child Care Disaster Relief/Child Care Development Block Grant/Child Care Mandatory and Matching Funds of the Child Care Development Fund (CCDF Cluster) 93.489/93.575/ 93.596/ COVID-19 93.575 Grant Award 2022 ? 2022G999005 Grant Award 2022 ? 2022G996005 Grant Award 2022 ? 2022G999004 Grant Award 2021 ? 2021G996005 Grant Award 2021 ? 2021G999005 Grant Award 2021 ? 2021G999004Criteria: 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 Department of Health & Human Resources (DHHR) has policies and procedures in place surrounding the review and approval of provider certifications in the application for funding and review and approval of verification of eligibility criteria; however, adequate documentation to test and determine that the controls were operating effectively was not available. Questioned Costs: N/A Context: Total federal expenditures for CCDF Cluster for the fiscal year ended June 30, 2022, were $196,326,309. Cause: Internal controls are not operating effectively surrounding the review and approval of provider certifications and verification of eligibility criteria. Effect: Providers who received ARP Act Stabilization funds may not have met the eligibility criteria or made the required certifications. Recommendation: We recommend that DHHR management maintain sufficient documentation to evidence its review and approval of provider certifications and eligibility criteria. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.