STATE OF WEST VIRGINIA
SINGLE AUDIT
TABLE OF CONTENTS
Page
Report of Independent Auditors on Internal Control over Financial
Reporting and on Compliance and Other Matters Based on an
Audit of Financial Statements Performed in Accordance with
Government Auditing Standards……............................................................................1
Report of Independent Auditors on Compliance for Each Major Federal
Program; Report on Internal Control Over Compliance and Report on
Schedule of Expenditures of Federal Awards Required by Uniform
Guidance..................................................................................................................................3

Schedule of Expenditures of Federal Awards…………..……....................................12

Notes to Schedule of Expenditures of Federal Awards .........................................24

Schedule of Findings and Questioned Costs…………….............................................28

Corrective Action Plan.......................................................................................................109
Summary Schedule of Prior Audit Findings.............................................................135

  

A 

REPORTS

 

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900 United Center
500 Virginia Street East
Charleston, WV 25301

Tel: +1 304 343 8971
Fax: +1 304 357 5994
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Report of Independent Auditors on Internal Control Over Financial Reporting and on
Compliance and Other Matters Based on an Audit of Financial Statements
Performed in Accordance with Government Auditing Standards
The Honorable Jim Justice, Governor
of the State of West Virginia
We have audited, in accordance with auditing standards generally accepted in the United States and the standards
applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the
United States, the financial statements of the governmental activities, the business-type activities, the aggregate
discretely presented component units, each major fund and the aggregate remaining fund information of the State of
West Virginia as of and for the year ended June 30, 2018, and the related notes to the financial statements, which
collectively comprise the State of West Virginia’s basic financial statements, and have issued our report thereon
dated December 21, 2018. Our report includes a reference to other auditors who audited the financial statements of
certain entities within the governmental activities, the business-type activities, the aggregate discretely presented
component units, certain major funds, and the aggregate remaining fund information as described in our report on
the State of West Virginia’s financial statements. This report does not include the results of the other auditors’ testing
of internal control over financial reporting or compliance and other matters that are reported on separately by those
auditors. The financial statements of the West Virginia Investment Management Board was not audited in accordance
with Government Auditing Standards, the West Virginia Housing Development Fund, School Building Authority of
West Virginia, and the following discretely presented component units of the Higher Education Fund discretely
presented component unit: Big Green Scholarship Foundation, Inc.; Bluefield State College Foundation, Inc.;
Bluefield State College Research and Development Corporation; Concord University Foundation, Inc.; Fairmont
State Foundation, Inc.; The Glenville State College Foundation, Inc.; The Marshall University Foundation, Inc.; New
River Community and Technical College Foundation, Inc.; Provident Group-Marshall Properties, LLC; The
Shepherd University Foundation, Inc.; Southern West Virginia Community College Foundation, Inc.; West Liberty
University Foundation, Inc.; West Virginia Northern Community College Foundation, Inc.; West Virginia School of
Osteopathic Medicine Foundation, Inc.; The West Virginia State University Foundation, Inc.; WVU at Parkersburg
Foundation, Inc; and BlueRidge Community and Technical College Foundation, Inc. were audited by other auditors
and were not performed in accordance with Government Auditing Standards.
Internal Control Over Financial Reporting
In planning and performing our audit of the financial statements, we considered the State of West Virginia’s internal
control over financial reporting (internal control) to determine the audit procedures that are appropriate in the
circumstances for the purpose of expressing our opinion on the financial statements, but not for the purpose of
expressing an opinion on the effectiveness of the State of West Virginia’s internal control. Accordingly, we do not
express an opinion on the effectiveness of the State of West Virginia’s internal control.
A deficiency in internal control exists when the design or operation of a control does not allow management or
employees, in the normal course of performing their assigned functions, to prevent, or detect and correct
misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal
control such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will
not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency or a combination
of deficiencies in internal control that is less severe than a material weakness, yet important enough to merit attention
by those charged with governance.

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 Our consideration of internal control was for the limited purpose described in the first paragraph and was not designed
to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and
therefore, material weaknesses or significant deficiencies may exist that have not been identified. We did identify
certain deficiencies in internal control described in the accompanying schedule of findings and questioned costs as
item 2018-001 that we consider to be material weakness.
Compliance and Other Matters
As part of obtaining reasonable assurance about whether the State of West Virginia’s financial statements are free of
material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts
and grant agreements, noncompliance with which could have a direct and material effect on the determination of
financial statement amounts. However, providing an opinion on compliance with those provisions was not an
objective of our audit and, accordingly, we do not express such an opinion. The results of our tests disclosed no
instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.
State of West Virginia’s Response to Findings
The State of West Virginia’s response to the findings identified in our audit is described in the accompanying
schedule of findings and questioned costs. The State of West Virginia’s response was not subjected to the auditing
procedures applied in the audit of the financial statements and, accordingly, we express no opinion on it.
Purpose of this Report
The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the
results of that testing, and not to provide an opinion on the effectiveness of the entity’s internal control or on
compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards
in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any
other purpose.

ey
December 21, 2018

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 Ernst & Young LLP
900 United Center
500 Virginia Street East
Charleston, WV 25301

Tel: +1 304 343 8971
Fax: +1 304 357 5994
ey.com

Report of Independent Auditors on Compliance for Each Major Federal Program;
Report on Internal Control Over Compliance and Report on Schedule of
Expenditures of Federal Awards Required by the Uniform Guidance
The Honorable Jim Justice, Governor
of the State of West Virginia
Report on Compliance for Each Major Federal Program
We have audited the State of West Virginia’s compliance with the types of compliance requirements described in
the U.S. Office of Management and Budget (OMB) Compliance Supplement that could have a direct and material
effect on each of the State of West Virginia’s major federal programs for the year ended June 30, 2018. The State of
West Virginia’s major federal programs are identified in the summary of auditor’s results section of the
accompanying schedule of findings and questioned costs. We did not audit the State of West Virginia’s compliance
with the compliance requirements referred to above that are applicable to the Capitalization Grant for Clean Water
Revolving Fund, that comprise expenditures of approximately $20.7 million. These compliance requirements were
audited by other auditors whose report thereon has been furnished to us. Our opinion on compliance, in so far as it
relates to the major program referred to above is based solely upon the report of other auditors.
The State of West Virginia’s basic financial statements include the operations of the West Virginia Housing
Development Fund (a proprietary fund), and the following discretely presented component units; the West Virginia
University Research Corporation, the West Virginia State University Research and Development Corporation,
Marshall University Research Corporation, and West Virginia Drinking Water Treatment Revolving Loan Fund
which expended $314,655,185 collectively, in federal awards which are not included in the State of West Virginia’s
schedule of expenditures of federal awards during the year ended June 30, 2018. Our audit, described below, did not
include the operations of this proprietary fund and these discretely presented component units, because they engaged
other auditors to perform an audit of compliance in accordance with audit requirements of Title 2 U.S. Code of
Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance).
Management’s Responsibility
Management is responsible for compliance with federal statutes, regulations and the terms and conditions of its
federal awards applicable to its federal programs.
Auditor’s Responsibility
Our responsibility is to express an opinion on compliance for each of the State of West Virginia’s major federal
programs based on our audit of the types of compliance requirements referred to above. We conducted our audit of
compliance in accordance with auditing standards generally accepted in the United States; the standards applicable
to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United
States; and the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Those standards
and the Uniform Guidance require that we plan and perform the audit to obtain reasonable assurance about whether
noncompliance with the types of compliance requirements referred to above that could have a direct and material
effect on a major federal program occurred. An audit includes examining, on a test basis, evidence about the State of
West Virginia’s compliance with those requirements and performing such other procedures as we considered
necessary in the circumstances.

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 We believe that our audit provides a reasonable basis for our adverse, qualified, and unmodified opinions on
compliance for major federal programs. However, our audit does not provide a legal determination of the State of
West Virginia’s compliance.
Basis for Adverse Opinion on Disaster Grants – Public Assistance (Presidentially Declared Disasters), Hazard
Mitigation Grant (HMGP), and Emergency Management Performance Grants
As described in the accompanying schedule of findings and questioned costs, the State of West Virginia did not
comply with requirements regarding the following, individually or in the aggregate:
Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–027

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Cash Management

2018–028

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Cash Management

2018–029

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Subrecipient Monitoring

2018–030

97.039

Hazard Mitigation Grant (HMGP)

Cash Management

2018–031

97.039

Hazard Mitigation Grant (HMGP)

Eligibility

2018–032

97.039

Hazard Mitigation Grant (HMGP)

Matching, Level of Effort and
Earmarking

2018–033

97.039

Hazard Mitigation Grant (HMGP)

Reporting

2018–034

97.039

Hazard Mitigation Grant (HMGP)

Subrecipient Monitoring

2018–035

97.042

Emergency Management Performance
Grants

Reporting

2018–036

97.042
Emergency Management Performance
Grants

Activities Allowed or
Unallowed and Allowable
Cost/Cost Principles

2018–037

97.042

Emergency Management Performance
Grants

Cash Management

2018–038

97.042

Emergency Management Performance
Grants

Eligibility

2018–039

97.042

Emergency Management Performance
Grants

Matching, Level of Effort and
Earmarking

2018–040

97.042

Emergency Management Performance
Grants

Matching, Level of Effort and
Earmarking

2018–041

97.042

Emergency Management Performance
Grants

Reporting

2018–042

97.042

Emergency Management Performance
Grants

Subrecipient Monitoring

2018–043

97.042

Emergency Management Performance
Grants

Special Tests and Provisions –
Closeout Reporting

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 Finding
Number
2018–044

CFDA Number
97.042

Program or Cluster Name
Emergency Management Performance
Grants

Compliance Requirement
Special Tests and Provisions –
Training Exercise Plan
Requirement

Compliance with such requirements is necessary, in our opinion, for the State of West Virginia to comply with
requirements applicable to those programs.
Adverse Opinion on Disaster Grants – Public Assistance (Presidentially Declared Disasters), Hazard Mitigation
Grant (HMGP), and Emergency Management Performance Grants
In our opinion, because of the significance of the matters discussed in the Basis for Adverse Opinion paragraph, the
State of West Virginia did not comply, in all material respects, with the types of compliance requirements referred
to above that could have a direct and material effect on Disaster Grants – Public Assistance (Presidentially Declared
Disasters), Hazard Mitigation Grant, and Emergency Management Performance Grants for the year ended June 30,
2018.
Basis for Qualified Opinion on National Guard Military Operations and Maintenance (O&M) Projects;
Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; Student
Financial Assistance Cluster; Temporary Assistance For Needy Families (TANF) Cluster; Low-Income Home
Energy Assistance; and Adoption Assistance
As described in the accompanying schedule of findings and questioned costs, the State of West Virginia did not
comply with requirements regarding the following, individually or in the aggregate:
Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–002

12.401

National Guard Military Operations and
Maintenance (O&M) Projects

Period of Availability of Federal
Funds/Period of Performance

2018–003

12.401

National Guard Military Operations and
Maintenance (O&M) Projects

Program Income

2018–004

14.228

Community Development Block
Reporting
Grants/State’s Program and Non-Entitlement
Grants in Hawaii

2018–005

14.228

Community Development Block
Activities Allowed or
Grants/State’s Program and Non-Entitlement Unallowed and Procurement and
Grants in Hawaii
Suspension and Debarment

2018–011

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Special Tests and Provisions –
Disbursements to or on Behalf
of Students

2018–012

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Special Tests and Provisions –
Enrollment Reporting

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 Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–018

93.558

Temporary Assistance for Needy Families
(TANF) Cluster

Reporting

2018–020

93.558

Temporary Assistance for Needy Families
(TANF) Cluster

Special Tests and Provisions –
Child Support Non-Cooperation

2018–021

93.568

Low-Income Home Energy Assistance

Activities Allowed or
Unallowed and Eligibility

2018–023

93.659

Adoption Assistance

Eligibility

Compliance with such requirements is necessary, in our opinion, for the State of West Virginia to comply with
requirements applicable to those programs.
Qualified Opinion on National Guard Military Operations and Maintenance (O&M) Projects; Community
Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; Student Financial
Assistance Cluster; Temporary Assistance For Needy Families (TANF) Cluster; Low-Income Home Energy
Assistance; and Adoption Assistance
In our opinion, except for the noncompliance described in the Basis for Qualified Opinion paragraph, the State of
West Virginia complied, in all material respects, with the types of compliance requirements referred to above that
could have a direct and material effect on National Guard Military Operations and Maintenance (O&M) Projects;
Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii; Student Financial
Assistance Cluster; Temporary Assistance For Needy Families (TANF) Cluster; Low-Income Home Energy
Assistance; and Adoption Assistance for the year ended June 30, 2018.
Unmodified Opinion on Each of the Other Major Federal Programs
In our opinion, the State of West Virginia complied, in all material respects, with the types of compliance
requirements referred to above that could have a direct and material effect on each of its other major federal programs
that are identified in the summary of auditors results section of the accompanying schedule of findings and questioned
costs for the year ended June 30, 2018.
Other Matters
The results of our auditing procedures disclosed other instances of noncompliance which are required to be reported
in accordance with the Uniform Guidance, and which are described in the accompanying schedule of findings and
questioned costs as items described and listed below:
Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–006

20.205/20.219/
20.224/23.003

Highways Planning and Construction Cluster Period of Performance

2018–008

20.205/20.219/
20.224/23.003

Highways Planning and Construction Cluster Special Tests and Provisions –
Wage Rate Requirements

2018–014

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Eligibility

2018–015

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Reporting

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 Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–016

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Special Tests and Provisions –
Completion of IPEs

2018–024

93.775/93.777/
93.778

Medicaid Cluster

Activities Allowed or
Unallowed and Allowable
Costs/Cost Principles

Our opinion on each major federal program is not modified with respect to these matters.
The State of West Virginia’s responses to the noncompliance findings identified in our audit are described in the
accompanying corrective action plan. The State of West Virginia’s response was not subjected to the auditing
procedures applied in the audit of compliance and, accordingly, we express no opinion on the responses.
Report on Internal Control Over Compliance
Management of the State of West Virginia is responsible for establishing and maintaining effective internal control
over compliance with the types of compliance requirements referred to above. In planning and performing our audit
of compliance, we considered the State of West Virginia’s internal control over compliance with the types of
requirements that could have a direct and material effect on each major federal program to determine the auditing
procedures that are appropriate in the circumstances for the purpose of expressing an opinion on compliance for each
major program and to test and report on internal control over compliance in accordance with the Uniform Guidance,
but not for the purpose of expressing an opinion on the effectiveness of internal control over compliance.
Accordingly, we do not express an opinion on the effectiveness of the State of West Virginia’s internal control over
compliance.
Our consideration of internal control over compliance was for the limited purpose described in the preceding
paragraph and was not designed to identify all deficiencies in internal control over compliance that might be material
weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that
have not been identified. However, as discussed below, we did identify certain deficiencies in internal control over
compliance that we consider to be material weaknesses and significant deficiencies.
A deficiency in internal control over compliance exists when the design or operation of a control over compliance
does not allow management or employees, in the normal course of performing their assigned functions, to prevent,
or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
A material weakness in internal control over compliance is a deficiency, or a combination of deficiencies, in internal
control over compliance, such that there is a reasonable possibility that material noncompliance with a type of
compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. We
consider the deficiencies in internal control over compliance described in the accompanying schedule of findings
and questioned costs and as listed below to be material weaknesses.
Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–002

12.401

National Guard Military Operations and
Maintenance (O&M) Projects

2018–004

14.228

Community Development Block
Reporting
Grants/State’s Program and Non-Entitlement
Grants in Hawaii

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Period of Availability of Federal
Funds/Period of Performance

 Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–005

14.228

Community Development Block
Activities Allowed or
Grants/State’s Program and Non-Entitlement Unallowed and Procurement and
Grants in Hawaii
Suspension and Debarment

2018–006

20.205/20.219/
20.224/23.003

Highways Planning and Construction Cluster Period of Performance

2018–012

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Special Tests and Provisions –
Enrollment Reporting

2018–017

93.558, 93.568,
93.575/93.596,
93.658, 93.659,
93.767, 93.775/
93.777/93.778

Temporary Assistance for Needy Families
(TANF) Cluster, Low-Income Home Energy
Assistance, Child Care and Development
Fund (CCDF) Cluster, Foster Care—Title
IV-E, Adoption Assistance, Children’s
Health Insurance Program (CHIP), Medicaid
Cluster

Activities Allowed or
Unallowed, Allowable
Costs/Cost Principles,
Eligibility; Level of Effort,
Special Tests and Provisions –
Operation of a Foster Care
Demonstration Project, Special
Tests and Provisions – Payment
Rate Setting and Application

2018–019

93.558

Temporary Assistance for Needy Families
(TANF) Cluster

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

2018–021

93.568

Low-Income Home Energy Assistance

Activities Allowed or
Unallowed and Eligibility

2018–022

93.575/93.596

Child Care and Development Fund (CCDF)
Cluster

Special Tests and Provisions –
Fraud Detection and Repayment
Controls

2018–023

93.659

Adoption Assistance

Eligibility

2018–027

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Cash Management

2018–028

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Cash Management

2018–029

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Subrecipient Monitoring

2018–030

97.039

Hazard Mitigation Grant (HMGP)

Cash Management

2018–031

97.039

Hazard Mitigation Grant (HMGP)

Eligibility

2018–034

97.039

Hazard Mitigation Grant (HMGP)

Subrecipient Monitoring

2018–036

97.042

Emergency Management Performance
Grants

Activities Allowed or
Unallowed

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 Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–037

97.042

Emergency Management Performance
Grants

Cash Management

2018–038

97.042

Emergency Management Performance
Grants

Eligibility

2018–039

97.042

Emergency Management Performance
Grants

Matching, Level of Effort and
Earmarking

2018–040

97.042

Emergency Management Performance
Grants

Matching, Level of Effort and
Earmarking

2018–041

97.042

Emergency Management Performance
Grants

Reporting

2018–042

97.042

Emergency Management Performance
Grants

Subrecipient Monitoring

2018–043

97.042

Emergency Management Performance
Grants

Special Tests and Provisions –
Closeout Reporting

2018–044

97.042

Emergency Management Performance
Grants

Special Tests and Provisions –
Training Exercise Plan
Requirement

A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in
internal control over compliance with a type of compliance requirement of a federal program that is less severe than
a material weakness, yet important enough to merit attention by those charged with governance. We consider the
deficiencies in internal control over compliance described in the accompanying schedule of findings and questioned
costs and as listed below to be significant deficiencies.
Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–003

12.401

National Guard Military Operations and
Maintenance (O&M) Projects

2018–007

20.205/20.219/
20.224/23.003

Highways Planning and Construction Cluster Reporting

2018–008

20.205/20.219/
20.224/23.003

Highways Planning and Construction Cluster Special Tests and Provisions –
Wage Rate Requirements

2018–009

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Reporting

2018–010

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Cash Management

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Program Income

 Finding
Number

CFDA Number

Program or Cluster Name

Compliance Requirement

2018–011

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Special Tests and Provisions –
Disbursements to or on Behalf
of Students

2018–013

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Student Financial Assistance Cluster

Special Tests and Provisions –
Borrower Data Transmission
and Reconciliation

2018–014

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Eligibility

2018–015

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Reporting

2018–016

84.126

Rehabilitation Services—Vocational
Rehabilitation Grants to State

Special Tests and Provisions –
Completion of IPES

2018–018

93.558

Temporary Assistance for Needy Families
(TANF) Cluster

Reporting

2018–024

93.775/93.777/
93.778

Medicaid Cluster

Activities Allowed or
Unallowed and Allowable
Costs/Cost Principles

2018–025

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Reporting

2018–026

97.036

Disaster Grants – Public Assistance
(Presidentially Declared Disasters)

Activities Allowed or
Unallowed

2018–032

97.039

Hazard Mitigation Grant (HMGP)

Matching, Level of Effort and
Earmarking

2018–033

97.039

Hazard Mitigation Grant (HMGP)

Reporting

2018–035

97.042

Emergency Management Performance
Grants

Reporting

The State of West Virginia’s responses to the internal control over compliance findings identified in our audit are
described in the accompanying schedule of findings and questioned costs and corrective action plan. The State of
West Virginia’s responses were not subjected to the auditing procedures applied in the audit of compliance and,
accordingly, we express no opinion on the responses.
The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal
control over compliance and the results of that testing based on the requirements of the Uniform Guidance.
Accordingly, this report is not suitable for any other purpose.

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 Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance
We have audited the financial statements of the State of West Virginia as of and for the year ended June 30, 2018,
and have issued our report thereon dated December 21, 2018, which contained an unmodified opinion on those
financial statements. Our audit was conducted for the purpose of forming an opinion on the financial statements as a
whole. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis
as required by the Uniform Guidance and is not a required part of the financial statements. Such information is the
responsibility of management and was derived from and relates directly to the underlying accounting and other
records used to prepare the financial statements. The information has been subjected to the auditing procedures
applied in the audit of the financial statements and certain additional procedures, including comparing and
reconciling such information directly to the underlying accounting and other records used to prepare the financial
statements or to the financial statements themselves, and other additional procedures in accordance with auditing
standards generally accepted in the United States. In our opinion, the schedule of expenditure of federal awards is
fairly stated in all material respects in relation to the financial statements as a whole.

ey

February 8, 2019

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 CH ED ULE 0F
EXPENDITURES
0F FEDERAL

AWARDS

 

STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

DEPARTMENT OF AGRICULTURE
10.025
PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE
10.028
WILDLIFE SERVICES
10.072
WETLANDS RESERVE PROGRAM
10.117
BIOFUEL INFRASTRUCTURE PARTNERSHIP
10.170
SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL
10.174
ACER ACCESS DEVELOPMENT PROGRAM
10.202***
COOPERATIVE FORESTRY RESEARCH
PAYMENTS TO AGRICULTURAL EXPERIMENT STATIONS UNDER THE
10.203***
HATCH ACT
10.207***
ANIMAL HEALTH AND DISEASE RESEARCH
10.216
1890 INSTITUTION CAPACITY BUILDING GRANTS
10.304
HOMELAND SECURITY AGRICULTURAL
10.310
AGRICULTURAL AND FOOD RESEARCH INITIATIVE (AFRI)
CROP PROTECTION AND PEST MANAGEMENT COMPETITIVE GRANTS
10.329
PROGRAM
COOPERATIVE AGREEMENTS WITH STATES FOR INTRASTATE MEAT
10.475
AND POULTRY INSPECTION
10.479
FOOD SAFETY COOPERATIVE AGREEMENTS
10.500
COOPERATIVE EXTENSION SERVICE
10.535
SNAP RECIPIENT INTEGRITY EDUCATION GRANT
10.547
PROFESSIONAL STANDARDS FOR SCHOOL NUTRITION EMPLOYEES
WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN,
10.557
INFANTS, AND CHILDREN
10.558
CHILD AND ADULT CARE FOOD PROGRAM
10.560
STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION
10.572
WIC FARMERS' MARKET NUTRITION PROGRAM (FMNP)
10.574
TEAM NUTRITION GRANTS
10.575
FARM TO SCHOOL GRANT PROGRAM
10.576
SENIOR FARMERS MARKET NUTRITION PROGRAM
10.579
CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY
10.582
FRESH FRUIT AND VEGETABLE PROGRAM
10.664
COOPERATIVE FORESTRY ASSISTANCE
SCHOOLS AND ROADS-GRANTS TO STATES AND FOREST SERVICE
10.665
SCHOOLS AND ROADS CLUSTER
10.676
FOREST LEGACY PROGRAM
10.678
FOREST STEWARDSHIP PROGRAM
10.680
FOREST HEALTH PROTECTION
10.684
INTERNATIONAL FORESTRY PROGRAMS
10.868
RURAL ENERGY FOR AMERICA PROGRAM
10.902
SOIL AND WATER CONSERVATION
10.903
SOIL SURVEY
10.912
ENVIRONMENTAL QUALITY INCENTIVES PROGRAM
10.913
FARM AND RANCH LANDS PROTECTION PROGRAM
10.916
WATERSHED REHABILITATION PROGRAM

10.551
10.561

SNAP CLUSTER
SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP)
STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL
NUTRITION ASSISTANCE PROGRAM
TOTAL SNAP CLUSTER

10.553
10.555
10.556
10.559

CHILD NUTRITION CLUSTER
SCHOOL BREAKFAST PROGRAM (SBP)
NATIONAL SCHOOL LUNCH PROGRAM (NSLP)
SPECIAL MILK PROGRAM FOR CHILDREN (SMP)
SUMMER FOOD SERVICE PROGRAM FOR CHILDREN (SFSPC)
TOTAL CHILD NUTRITION CLUSTER

10.565
10.568
10.569

FOOD DISTRIBUTION CLUSTER
COMMODITY SUPPLEMENTAL FOOD PROGRAM
EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS)
EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES)
TOTAL FOOD DISTRIBUTION CLUSTER

12

$640,252
$8,908
$8,738
$0
$73,076
$5,782
$654,977

$0
$0
$0
$1,059,374
$142,470
$0
$0

$640,252
$8,908
$8,738
$1,059,374
$215,546
$5,782
$654,977

$3,447,496
$15,200
$291
$22,144
$10,742

$0
$0
$0
$0
$0

$3,447,496
$15,200
$291
$22,144
$10,742

$922

$0

$922

$589,505
$252,215
$4,671,402
$4,367
$0

$0
$0
$75,951
$0
$31,500

$589,505
$252,215
$4,747,353
$4,367
$31,500

$20,083,903
$67,161
$2,807,284
$57,933
$0
$13,022
$463,279
$0
$41,264
$919,629

$9,012,621
$17,144,899
$0
$0
($25,034)
$0
$0
$161,301
$1,652,597
$139,675

$29,096,524
$17,212,060
$2,807,284
$57,933
($25,034)
$13,022
$463,279
$161,301
$1,693,861
$1,059,304

$1,685,549
$38,570
$22,640
$356,044
$31,908
$92,440
$218,097
$2,752
$248,535
$33,323
$3,505,943

$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0

$1,685,549
$38,570
$22,640
$356,044
$31,908
$92,440
$218,097
$2,752
$248,535
$33,323
$3,505,943

$451,228,131

$0

$451,228,131

$17,071,522
$468,299,653

$3,890,256
$3,890,256

$20,961,778
$472,189,909

$146,445
$10,306,632
$0
$3,792
$10,456,869

$41,713,600
$79,529,197
$11,992
$1,873,784
$123,128,573

$41,860,045
$89,835,829
$11,992
$1,877,576
$133,585,442

$1,255,783
$20,271
$3,857,467
$5,133,521

$370,655
$557,426
$0
$928,081

$1,626,438
$577,697
$3,857,467
$6,061,602

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

10.U01

THE IMPACT OF CLIMATE CHANGE ON COASTAL ALASKA FOREST
CARBON SEQUESTRATION

10.U02

NATIONAL VISITOR USE MONITORING

$6,874

$0

$6,874

$185,354

$62,461

$247,815

$1
$525,177,565

$0
$157,404,725

$1
$682,582,290

DEPARTMENT OF COMMERCE
ECONOMIC ADJUSTMENT ASSISTANCE AND ECONOMIC DEVELOPMENT
11.307
CLUSTER
11.549
STATE AND LOCAL IMPLEMENTATION GRANT PROGRAM
ARRA - STATE BROADBAND DATA AND DEVELOPMENT GRANT
11.558
PROGRAM

$153,534
$134,223

$0
$0

$153,534
$134,223

$4,574

$0

$4,574

11.620
SCIENCE, TECHNOLOGY, BUSINESS AND/OR EDUCATION OUTREACH
TOTAL DEPARTMENT OF COMMERCE

$40,377
$332,708

$0
$0

$40,377
$332,708

$919

$0

$919

$184,879
$582,383

$0
$0

$184,879
$582,383

$25,604,542
$5,478,352

$0
$0

$25,604,542
$5,478,352

$235,193

$184,313

$419,506

$95,653
$22,308
$49,045
$32,253,274

$0
$67,414
$0
$251,727

$95,653
$89,722
$49,045
$32,505,001

$71,241

$0

$71,241

$1,991,044
$36,793
$7,293
$45,059
$2,151,430

$14,079,770
$1,338,393
$351,709
$0
$15,769,872

$16,070,814
$1,375,186
$359,002
$45,059
$17,921,302

$10,779,392
$43,166,770

$0
$15,740,938

$10,779,392
$58,907,708

$107,269
$263,680
$38,845
$113,916
$635,573

$7,755
$229
$0
$0
$0

$115,024
$263,909
$38,845
$113,916
$635,573

$47,353
$3,659
$77,002
$50,160
$2,301
$672,403

$0
$0
$0
$0
$0
$192,962

$47,353
$3,659
$77,002
$50,160
$2,301
$865,365

$2,301
($26,600)
$243,469

$674,447
$0
$0

$676,748
($26,600)
$243,469

$7,100
$32,420

$0
$0

$7,100
$32,420

10.U03
REGION 6 ROUND 3 NVUM
TOTAL DEPARTMENT OF AGRICULTURE

DEPARTMENT OF DEFENSE
12.002
PROCUREMENT TECHNICAL ASSISTANCE FOR BUSINESS FIRMS
STATE MEMORANDUM OF AGREEMENT PROGRAM FOR THE
12.113
REIMBURSEMENT OF TECHNICAL SERVICES
12.400
MILITARY CONSTRUCTION, NATIONAL GUARD
NATIONAL GUARD MILITARY OPERATIONS AND MAINTENANCE (O&M)
12.401
PROJECTS
12.404
NATIONAL GUARD CHALLENGE PROGRAM
12.617

ECONOMIC ADJUSTMENT ASSISTANCE FOR STATE GOVERNMENTS
BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND
12.630
ENGINEERING
12.900
LANGUAGE GRANT PROGRAM
12.902
INFORMATION SECURITY GRANT PROGRAM
TOTAL DEPARTMENT OF DEFENSE
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
MANUFACTURED HOME LOAN INSURANCE-FINANCING PURCHASE OF
MANUFACTURED HOMES AS PRINCIPAL RESIDENCES OF BORROWERS
COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND
14.228
NON-ENTITLEMENT GRANTS IN HAWAII
14.231
EMERGENCY SOLUTIONS GRANT PROGRAM
14.241
HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS
14.400
EQUAL OPPORTUNITY IN HOUSING
TOTAL DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
14.110

DEPARTMENT OF THE INTERIOR
REGULATION OF SURFACE COAL MINING AND SURFACE EFFECTS OF
15.250
UNDERGROUND COAL MINING
15.252
ABANDONED MINE LAND RECLAMATION (AMLR)
SCIENCE AND TECHNOLOGY PROJECTS RELATED TO COAL MINING
15.255
AND RECLAMATION
15.433
FLOOD CONTROL ACT LANDS
15.608
FISH AND WILDLIFE MANAGEMENT ASSISTANCE
15.615
COOPERATIVE ENDANGERED SPECIES CONSERVATION FUND
15.634
STATE WILDLIFE GRANTS
ENDANGERED SPECIES CONSERVATION - RECOVERY
15.657
IMPLEMENTATION FUNDS
15.808
U.S. GEOLOGICAL SURVEY - RESEARCH AND DATA COLLECTION
15.810
NATIONAL COOPERATIVE GEOLOGIC MAPPING
15.812
COOPERATIVE RESEARCH UNITS PROGRAM
15.814
NATIONAL GEOLOGICAL AND GEOPHYSICAL DATA PRESERVATION
15.904
HISTORIC PRESERVATION FUND GRANTS-IN-AID
15.916
15.922
15.939
15.945
15.981

OUTDOOR RECREATION-ACQUISITION, DEVELOPMENT AND PLANNING
NATIVE AMERICAN GRAVES PROTECTION AND REPATRIATION ACT
NATIONAL HERITAGE AREA FEDERAL FINANCIAL ASSISTANCE
COOPERATIVE RESEARCH AND TRAINING PROGRAMS - RESOURCES
OF THE NATIONAL PARK SYSTEM
WATER USE AND DATA RESEARCH

13

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

15.605
15.611

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

FISH AND WILDLIFE CLUSTER
SPORT FISH RESTORATION
WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION
TOTAL FISH AND WILDLIFE CLUSTER

15.U04
WV COOPERATIVE FISH AND WILDLIFE RESEARCH UNIT
TOTAL DEPARTMENT OF THE INTERIOR
DEPARTMENT OF JUSTICE
16.017
SEXUAL ASSAULT SERVICES FORMULA PROGRAM
GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE,
16.525
SEXUAL ASSAULT, AND STALKING ON CAMPUS
16.540
JUVENILE JUSTICE AND DELINQUENCY PREVENTION
16.543
MISSING CHILDREN'S ASSISTANCE
STATE JUSTICE STATISTICS PROGRAM FOR STATISTICAL ANALYSIS
16.550
CENTERS
16.554
NATIONAL CRIMINAL HISTORY IMPROVEMENT PROGRAM (NCHIP)
CRIMINAL JUSTICE RESEARCH AND DEVELOPMENT-GRADUATE
16.562
RESEARCH FELLOWSHIPS
16.575
CRIME VICTIM ASSISTANCE
16.576
CRIME VICTIM COMPENSATION
16.582
CRIME VICTIM ASSISTANCE/DISCRETIONARY GRANTS
16.585
DRUG COURT DISCRETIONARY GRANT PROGRAM
16.588
VIOLENCE AGAINST WOMEN FORMULA GRANTS
RURAL DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT,
16.589
AND STALKING ASSISTANCE PROGRAM
GRANTS TO ENCOURAGE ARREST POLICIES AND ENFORCEMENT OF
16.590
PROTECTION ORDERS PROGRAM

$11,084,696
$4,075,123
$15,159,819

$0
$0
$0

$11,084,696
$4,075,123
$15,159,819

$44,018
$71,420,850

$0
$16,616,331

$44,018
$88,037,181

$4,947

$362,402

$367,349

$158,928
$53,487
$333,555

$0
$548,471
$0

$158,928
$601,958
$333,555

$45,362
$653,095

$71,280
$0

$116,642
$653,095

$105,398
$103,079
$1,159,000
$297,619
$457,363
$125,325

$0
$3,856,307
$0
$2,972,601
$0
$956,747

$105,398
$3,959,386
$1,159,000
$3,270,220
$457,363
$1,082,072

$6,407

$159,686

$166,093

$52,056

$169,393

$221,449

16.593

RESIDENTIAL SUBSTANCE ABUSE TREATMENT FOR STATE PRISONERS

$47,669

$43,346

$91,015

16.710

PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS

$52,820

$0

$52,820

16.735

PREA PROGRAM: STRATEGIC SUPPORT FOR PREA IMPLEMENTATION

$410,522

$47,899

$458,421

16.738
16.741

EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM
DNA BACKLOG REDUCTION PROGRAM
PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT
PROGRAM
NICS ACT RECORD IMPROVEMENT PROGRAM

$214,697
$427,065

$297,564
$0

$512,261
$427,065

$49,126
$1,847,798

$62,843
$0

$111,969
$1,847,798

$33,002
($3,799)
$67,211
$1,941
$232
$679,132
$129,024
$155,503
$7,667,564

$0
$0
$73,851
$0
$0
$0
$0
$0
$9,622,390

$33,002
($3,799)
$141,062
$1,941
$232
$679,132
$129,024
$155,503
$17,289,954

$669,420
$87,624
$360,863,179
$35,737
$2,621,649
$4,690
$346
$796,295
$1,034,559
$83,192
$39,957

$0
$0
$0
$768,695
$0
$0
$0
$0
$0
$0
$0

$669,420
$87,624
$360,863,179
$804,432
$2,621,649
$4,690
$346
$796,295
$1,034,559
$83,192
$39,957

16.742
16.813

16.816
JOHN R. JUSTICE PROSECUTORS AND DEFENDERS INCENTIVE ACT
16.817
INNOVATIONS IN COMMUNITY-BASED CRIME REDUCTION
16.833
NATIONAL SEXUAL ASSAULT KIT INITIATIVE
16.838
COMPREHENSIVE OPIOID ABUSE SITE-BASED PROGRAM
16.922
EQUITABLE SHARING PROGRAM
16.U05
MISCELLANEOUS JUSTICE PROGRAMS
16.U06
EQUITABLE SHARING PROGRAM-JUSTICE
16.U07
PURDUE PHARMA SETTLEMENT
TOTAL DEPARTMENT OF JUSTICE
DEPARTMENT OF LABOR
17.002
17.005
17.225
17.235
17.245
17.260
17.266
17.268
17.269
17.271
17.273

LABOR FORCE STATISTICS
COMPENSATION AND WORKING CONDITIONS
UNEMPLOYMENT INSURANCE (NOTE 4)
SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM
TRADE ADJUSTMENT ASSISTANCE
WIA - DISLOCATED WORKERS
WORK INCENTIVE GRANTS
H-1B JOB TRAINING GRANTS
COMMUNITY BASED JOB TRAINING GRANTS
WORK OPPORTUNITY TAX CREDIT PROGRAM (WOTC)
TEMPORARY LABOR CERTIFICATION FOR FOREIGN WORKERS

14

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

17.282
17.285
17.504
17.600
17.U08

WIOA NATIONAL DISLOCATED WORKER GRANTS/WIA NATIONAL
EMERGENCY GRANTS
WIOA DISLOCATED WORKER NATIONAL RESERVE TECHNICAL
ASSISTANCE AND TRAINING
TRADE ADJUSTMENT ASSISTANCE COMMUNITY COLLEGE AND
CAREER TRAINING (TAACCCT) GRANTS
APPRENTICESHIP USA GRANTS
CONSULTATION AGREEMENTS
MINE HEALTH AND SAFETY GRANTS
MISCELLANEOUS LABOR PROGRAMS

17.207
17.801

EMPLOYMENT SERVICE CLUSTER
EMPLOYMENT SERVICE/WAGNER-PEYSER FUNDED ACTIVITIES
DISABLED VETERANS' OUTREACH PROGRAM (DVOP)

$6,115,151
$777,800

$0
$0

$6,115,151
$777,800

LOCAL VETERANS' EMPLOYMENT REPRESENTATIVE (LVER) PROGRAM
TOTAL EMPLOYMENT SERVICE CLUSTER

$114,297
$7,007,248

$0
$0

$114,297
$7,007,248

WIOA CLUSTER
WIA/WIOA ADULT PROGRAM
WIA/WIOA YOUTH ACTIVITIES
WIA/WIOA DISLOCATED WORKER FORMULA GRANTS
TOTAL WIOA CLUSTER

$685,416
$718,226
$748,354
$2,151,996

$4,244,955
$4,606,654
$4,886,937
$13,738,546

$4,930,371
$5,324,880
$5,635,291
$15,890,542

$381,049,609

$20,702,661

$401,752,270

$9,504
$9,504

$0
$0

$9,504
$9,504

$372,529,181
$2,124,039
$1,133,655
$14,635
$1,310,191

$4,049,462
$0
$651,676
$0
$0

$376,578,643
$2,124,039
$1,785,331
$14,635
$1,310,191

$9,869

$0

$9,869

$3,593
$1,003,519

$41,387
$7,033,521

$44,980
$8,037,040

$1,465,302

$1,320,707

$2,786,009

$11,627

$10,058

$21,685

$195,314
$3,386,194

$0
$34,893

$195,314
$3,421,087

$52,466
$650,144

$0
$0

$52,466
$650,144

$15,083

$22,978

$38,061

$282,942
$7,254,466

$0
$0

$282,942
$7,254,466

$37,136
$86,726
$451,723
$575,585

$0
$0
$0
$0

$37,136
$86,726
$451,723
$575,585

17.277
17.281

17.804

17.258
17.259
17.278

TOTAL DEPARTMENT OF LABOR

$1,041,724

$6,195,420

$7,237,144

$1,578

$0

$1,578

$3,357,977
$63,169
$354,573
$488,713
$345,983

$0
$0
$0
$0
$0

$3,357,977
$63,169
$354,573
$488,713
$345,983

DEPARTMENT OF STATE
19.009
ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS
TOTAL DEPARTMENT OF STATE
DEPARTMENT OF TRANSPORTATION
20.205*
HIGHWAY PLANNING AND CONSTRUCTION
20.218
MOTOR CARRIER SAFETY ASSISTANCE
20.219*
RECREATIONAL TRAILS PROGRAM
20.224*
FEDERAL LANDS ACCESS PROGRAM
20.232
COMMERCIAL DRIVER'S LICENSE PROGRAM IMPLEMENTATION GRANT
MOTOR CARRIER SAFETY ASSISTANCE HIGH PRIORITY GRANTS AND
20.237
COOPERATIVE AGREEMENTS
METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON20.505
METROPOLITAN PLANNING AND RESEARCH
20.509
FORMULA GRANTS FOR RURAL AREAS
ENHANCED MOBILITY FOR SENIORS AND INDIVIDUALS WITH
20.513
DISABILITIES AND TRANSIT SERVICES PROGRAMS CLUSTER
PUBLIC TRANSPORTATION RESEARCH, TECHNICAL ASSISTANCE, AND
20.514
TRAINING
RAIL FIXED GUIDEWAY PUBLIC TRANSPORTATION SYSTEM STATE
20.528
SAFETY OVERSIGHT FORMULA GRANT PROGRAM
20.607
ALCOHOL OPEN CONTAINER REQUIREMENTS

20.614
20.700
20.703
20.724
20.933

20.500
20.525
20.526

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION (NHTSA)
DISCRETIONARY SAFETY GRANTS AND COOPERATIVE AGREEMENTS
PIPELINE SAFETY PROGRAM STATE BASE GRANT
INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING
AND PLANNING GRANTS
PIPELINE SAFETY RESEARCH COMPETITIVE ACADEMIC AGREEMENT
PROGRAM (CAAP)
NATIONAL INFRASTRUCTURE INVESTMENTS
FEDERAL TRANSIT CLUSTER
FEDERAL TRANSIT - CAPITAL INVESTMENT GRANTS
STATE OF GOOD REPAIR GRANTS PROGRAM
BUS AND BUS FACILITIES FORMULA PROGRAM
TOTAL FEDERAL TRANSIT CLUSTER

15

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

20.600

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

HIGHWAY SAFETY CLUSTER
STATE AND COMMUNITY HIGHWAY SAFETY
ALCOHOL IMPAIRED DRIVING COUNTERMEASURES INCENTIVE
GRANTS l
SAFETY BELT PERFORMANCE GRANTS
STATE TRAFFIC SAFETY INFORMATION SYSTEM IMPROVEMENTS
GRANTS
INCENTIVE GRANT PROGRAM TO INCREASE MOTORCYCLIST SAFETY
CHILD SAFETY AND CHILD BOOSTER SEAT INCENTIVE GRANTS
NATIONAL PRIORITY SAFETY PROGRAMS
TOTAL HIGHWAY SAFETY CLUSTER

$972,889

$1,133,123

$2,106,012

$409,655
$0

$0
$33,678

$409,655
$33,678

$0
$26,519
$1,309
$1,087,687
$2,498,059

$90,160
$1,551
$0
$1,294,660
$2,553,172

$90,160
$28,070
$1,309
$2,382,347
$5,051,231

$25,551
$125,331
$394,666,746

$0
$0
$15,717,854

$25,551
$125,331
$410,384,600

$691,703
$252,010
$13,048,788

$0
$329,806
$0

$691,703
$581,816
$13,048,788

$108,658
$14,101,159

$0
$329,806

$108,658
$14,430,965

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
EMPLOYMENT DISCRIMINATION-TITLE VII OF THE CIVIL RIGHTS ACT OF
30.001
1964
TOTAL EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

$88,716
$88,716

$0
$0

$88,716
$88,716

GENERAL SERVICES ADMINISTRATION
39.003
DONATION OF FEDERAL SURPLUS PERSONAL PROPERTY
TOTAL GENERAL SERVICES ADMINISTRATION

$71,923
$71,923

$0
$0

$71,923
$71,923

$278,017
$16,805
$294,822

$0
$0
$0

$278,017
$16,805
$294,822

$320,425

$190,970

$511,395

$5,994
$144,247
$747,616
$1,218,282

$0
$0
$394,217
$585,187

$5,994
$144,247
$1,141,833
$1,803,469

$7,250
$11,854
$457,681

$0
$0
$0

$7,250
$11,854
$457,681

$413,541
$19,099
$909,425

$3,729,423
$0
$3,729,423

$4,142,964
$19,099
$4,638,848

$804,423
$53,000
$857,423

$0
$110,817
$110,817

$804,423
$163,817
$968,240

DEPARTMENT OF VETERANS AFFAIRS
64.015
VETERANS STATE NURSING HOME CARE
64.028
POST-9/11 VETERANS EDUCATIONAL ASSISTANCE
64.124
ALL-VOLUNTEER FORCE EDUCATIONAL ASSISTANCE

$10,984,343
$302,318
$160,502

$0
$0
$0

$10,984,343
$302,318
$160,502

64.U11
PREVENTABLE HOSPITALIZATIONS AMONG VETERANS WITH DIABETES
TOTAL DEPARTMENT OF VETERANS AFFAIRS

$86,970
$11,534,133

$0
$0

$86,970
$11,534,133

20.601
20.609
20.610
20.612
20.613
20.616

20.U09
WV DOT PHASE III TRAILS PROJECT
20.U10
WV DOT PHASE II SCANNING PROJECT
TOTAL DEPARTMENT OF TRANSPORTATION
APPALACHIAN REGIONAL COMMISSION
23.001
APPALACHIAN REGIONAL DEVELOPMENT
23.002
APPALACHIAN AREA DEVELOPMENT
23.003*
APPALACHIAN DEVELOPMENT HIGHWAY SYSTEM
APPALACHIAN RESEARCH, TECHNICAL ASSISTANCE, AND
23.011
DEMONSTRATION PROJECTS
TOTAL APPALACHIAN REGIONAL COMMISSION

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
43.001
SCIENCE
43.008
EDUCATION (NOTE 3)
TOTAL NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
INSTITUTE OF MUSEUM AND LIBRARY SERVICES
45.025
PROMOTION OF THE ARTS-PARTNERSHIP AGREEMENTS
PROMOTION OF THE HUMANITIES - DIVISION OF PRESERVATION AND
45.149
ACCESS
45.163
PROMOTION OF THE HUMANITIES-PROFESSIONAL DEVELOPMENT
45.310
GRANTS TO STATES
TOTAL INSTITUTE OF MUSEUM AND LIBRARY SERVICES
NATIONAL SCIENCE FOUNDATION
47.041***
ENGINEERING GRANTS
47.049***
MATHEMATICAL AND PHYSICAL SCIENCES
47.076***
EDUCATION AND HUMAN RESOURCES
OFFICE OF EXPERIMENTAL PROGRAM TO STIMULATE COMPETITIVE
47.081***
RESEARCH
47.083***
OFFICE OF INTEGRATIVE ACTIVITIES
TOTAL NATIONAL SCIENCE FOUNDATION
SMALL BUSINESS ADMINISTRATION
59.037
SMALL BUSINESS DEVELOPMENT CENTERS
59.061
STATE TRADE EXPANSION
TOTAL SMALL BUSINESS ADMINISTRATION

16

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

ENVIRONMENTAL PROTECTION AGENCY
66.001
AIR POLLUTION CONTROL PROGRAM SUPPORT
66.032
STATE INDOOR RADON GRANTS
SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS,
AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT
MULTIPURPOSE GRANTS TO STATES AND TRIBES
WATER POLLUTION CONTROL STATE, INTERSTATE, AND TRIBAL
66.419
PROGRAM SUPPORT
66.432
STATE PUBLIC WATER SYSTEM SUPERVISION
66.433
STATE UNDERGROUND WATER SOURCE PROTECTION
66.454
WATER QUALITY MANAGEMENT PLANNING
CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING
66.458
FUNDS AND CLEAN WATER STATE REVOLVING FUND CLUSTER
66.460
NONPOINT SOURCE IMPLEMENTATION GRANTS
66.461
REGIONAL WETLAND PROGRAM DEVELOPMENT GRANTS
66.466
CHESAPEAKE BAY PROGRAM
CAPITALIZATION GRANTS FOR DRINKING WATER STATE REVOLVING
66.468
FUNDS AND DRINKING WATER STATE REVOLVING FUND CLUSTER
66.605
PERFORMANCE PARTNERSHIP GRANTS
ENVIRONMENTAL INFORMATION EXCHANGE NETWORK GRANT
66.608
PROGRAM AND RELATED ASSISTANCE
TOXIC SUBSTANCES COMPLIANCE MONITORING COOPERATIVE
66.701
AGREEMENTS
TSCA TITLE IV STATE LEAD GRANTS CERTIFICATION OF LEAD-BASED
66.707
PAINT PROFESSIONALS
66.708
POLLUTION PREVENTION GRANTS PROGRAM
66.801
HAZARDOUS WASTE MANAGEMENT STATE PROGRAM SUPPORT
SUPERFUND STATE, POLITICAL SUBDIVISION, AND INDIAN TRIBE SITE66.802
SPECIFIC COOPERATIVE AGREEMENTS
UNDERGROUND STORAGE TANK PREVENTION, DETECTION AND
66.804
COMPLIANCE PROGRAM
LEAKING UNDERGROUND STORAGE TANK TRUST FUND CORRECTIVE
66.805
ACTION PROGRAM
SUPERFUND STATE AND INDIAN TRIBE CORE PROGRAM COOPERATIVE
66.809
AGREEMENTS
66.817
STATE AND TRIBAL RESPONSE PROGRAM GRANTS
BROWNFIELD ASSESSMENT AND CLEANUP COOPERATIVE
66.818
AGREEMENTS
66.U12
OPERATIONALIZING WETLAND FUNCTIONAL ASSESSMENT IN WV
66.U13
MISC. FEDERAL AWARD PROGRAMS
ENVIRONMENTAL PROTECTION AGENCY
66.034
66.204

DEPARTMENT OF ENERGY
81.041
STATE ENERGY PROGRAM
81.042
WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS
81.057
UNIVERSITY COAL RESEARCH
81.086
CONSERVATION RESEARCH AND DEVELOPMENT
81.087
RENEWABLE ENERGY RESEARCH AND DEVELOPMENT
81.089***
FOSSIL ENERGY RESEARCH AND DEVELOPMENT (NOTE 3)
ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION
DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL
81.117
ANALYSIS/ASSISTANCE
81.119
STATE ENERGY PROGRAM SPECIAL PROJECTS
TOTAL DEPARTMENT OF ENERGY
DEPARTMENT OF EDUCATION
84.002
ADULT EDUCATION - BASIC GRANTS TO STATES
FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS
84.007**
(FSEOG)
84.010
TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES
TITLE I STATE AGENCY PROGRAM FOR NEGLECTED AND DELINQUENT
84.013
CHILDREN AND YOUTH

17

$1,430,024
$20,047

$0
$52,708

$1,430,024
$72,755

$354,110
$160,811

$0
$0

$354,110
$160,811

$2,069,591
$608,461
$157,151
$149,859

$40,000
$0
$0
$35,012

$2,109,591
$608,461
$157,151
$184,871

$0
$892,409
$180,345
$1,367,118

$20,668,000
$577,166
$0
$385,168

$20,668,000
$1,469,575
$180,345
$1,752,286

$2,673,257
$344,096

$304,264
$0

$2,977,521
$344,096

$2,613

$0

$2,613

$121,626

$0

$121,626

$99,024
$89,143
$1,832,932

$0
$0
$0

$99,024
$89,143
$1,832,932

$344,715

$0

$344,715

$435,882

$0

$435,882

$355,838

$0

$355,838

$129,530
$487,761

$0
$0

$129,530
$487,761

$147,054
$46,589
($934,395)
$13,565,591

$0
$0
$0
$22,062,318

$147,054
$46,589
($934,395)
$35,627,909

$507,538
$189,393
$75,382
$19,676
$7,988
$96,069

$10,939
$2,888,800
$0
$0
$0
$0

$518,477
$3,078,193
$75,382
$19,676
$7,988
$96,069

$206,434
$48,090
$1,150,570

$0
$47,301
$2,947,040

$206,434
$95,391
$4,097,610

$976,496

$2,946,053

$3,922,549

$3,423,531
$731,543

$0
$81,979,527

$3,423,531
$82,711,070

$843,853

$0

$843,853

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

84.031
84.033**

HIGHER EDUCATION-INSTITUTIONAL AID
FEDERAL WORK-STUDY PROGRAM (FWS)

84.038**
84.048
84.063**

FEDERAL PERKINS LOAN (FPL) - FEDERAL CAPITAL CONTRIBUTIONS
CAREER AND TECHNICAL EDUCATION-BASIC GRANTS TO STATES
FEDERAL PELL GRANT PROGRAM (PELL)
REHABILITATION SERVICES-VOCATIONAL REHABILITATION GRANTS TO
STATES
INDEPENDENT LIVING-STATE GRANTS
INDEPENDENT LIVING SERVICES FOR OLDER INDIVIDUALS WHO ARE
BLIND
SPECIAL EDUCATION - GRANTS FOR INFANTS AND FAMILIES
SUPPORTED EMPLOYMENT SERVICES FOR INDIVIDUALS WITH THE
MOST SIGNIFICANT DISABILITIES
EDUCATION FOR HOMELESS CHILDREN AND YOUTH
FEDERAL DIRECT STUDENT LOANS
TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS
SPECIAL EDUCATION-TECHNICAL ASSISTANCE AND DISSEMINATION
TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH
DISABILITIES
ADVANCED PLACEMENT PROGRAM (ADVANCED PLACEMENT TEST
FEE; ADVANCED PLACEMENT INCENTIVE PROGRAM GRANTS)
GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE
PROGRAMS
CHILD CARE ACCESS MEANS PARENTS IN SCHOOL
RURAL EDUCATION
ENGLISH LANGUAGE ACQUISITION STATE GRANTS
MATHEMATICS AND SCIENCE PARTNERSHIPS
SUPPORTING EFFECTIVE INSTRUCTION STATE GRANT
GRANTS FOR STATE ASSESSMENTS AND RELATED ACTIVITIES
NATIONAL SCIENCE AND MATHEMATICS ACCESS TO RETAIN TALENT
(SMART) GRANTS (SMART GRANTS)
SCHOOL IMPROVEMENT GRANTS
TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER
EDUCATION GRANTS (TEACH GRANTS)
STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM

84.126
84.169
84.177
84.181
84.187
84.196
84.268**
84.287

84.326
84.330
84.334
84.335
84.358
84.365
84.366
84.367
84.369
84.376
84.377
84.379**
84.424

$4,377,142
$3,452,078

$0
$0

$4,377,142
$3,452,078

$45,808,627
$3,473,321
$113,928,606

$0
$5,708,405
$0

$45,808,627
$9,181,726
$113,928,606

$30,070,708
$0

$236,639
$332,458

$30,307,347
$332,458

$441,279
$1,772,469

$0
$419,887

$441,279
$2,192,356

$213,152
$58,468
$450,828,066
$287,090

$0
$283,403
$0
$6,307,079

$213,152
$341,871
$450,828,066
$6,594,169

$76,889

$26,845

$103,734

$0

$55,489

$55,489

$1,668,144
$65,821
$24,819
$141,722
$759,881
$466,246
$2,043,654

$601,384
$0
$1,820,953
$535,805
$304,874
$14,942,965
$0

$2,269,528
$65,821
$1,845,772
$677,527
$1,064,755
$15,409,211
$2,043,654

$65,870
$28,361

$0
$949,961

$65,870
$978,322

$475,032
$57,048

$0
$397,003

$475,032
$454,051

84.027
84.173

SPECIAL EDUCATION CLUSTER (IDEA)
SPECIAL EDUCATION-GRANTS TO STATES (IDEA, PART B)
SPECIAL EDUCATION-PRESCHOOL GRANTS (IDEA PRESCHOOL)
TOTAL SPECIAL EDUCATION CLUSTER (IDEA)

$6,885,131
$434,552
$7,319,683

$67,003,787
$2,754,883
$69,758,670

$73,888,918
$3,189,435
$77,078,353

84.042
84.044
84.047
84.066
84.217

TRIO CLUSTER
TRIO-STUDENT SUPPORT SERVICES
TRIO-TALENT SEARCH
TRIO-UPWARD BOUND
TRIO-EDUCATIONAL OPPORTUNITY CENTERS
TRIO-MCNAIR POST-BACCALAUREATE ACHIEVEMENT
TOTAL TRIO CLUSTER

$1,571,584
$207,223
$1,700,897
$156,115
$294,501
$3,930,320

$0
$0
$0
$0
$0
$0

$1,571,584
$207,223
$1,700,897
$156,115
$294,501
$3,930,320

84.U14
NATIONAL ASSESSMENT OF EDUCATIONAL PROGRESS
TOTAL DEPARTMENT OF EDUCATION

$127,295
$677,937,214

$0
$187,607,400

$127,295
$865,544,614

ELECTION ASSISTANCE COMMISSION
90.401
HELP AMERICA VOTE ACT REQUIREMENTS PAYMENTS
TOTAL ELECTION ASSISTANCE COMMISSION

$221,001
$221,001

$0
$0

$221,001
$221,001

$138

$0

$138

$564

$25,000

$25,564

$86,036

$11,488

$97,524

DEPARTMENT OF HEALTH AND HUMAN SERVICES
93.003
PUBLIC HEALTH AND SOCIAL SERVICES EMERGENCY FUND
SPECIAL PROGRAMS FOR THE AGING-TITLE VII, CHAPTER 3PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND
93.041
EXPLOITATION
SPECIAL PROGRAMS FOR THE AGING-TITLE VII, CHAPTER 2-LONG
93.042
TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS

18

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

93.043
93.048
93.051
93.052
93.069
93.070
93.071
93.073

93.074

93.079
93.090
93.092
93.094
93.103
93.110
93.116
93.127
93.130
93.135
93.136
93.150
93.165
93.217
93.234
93.235
93.236
93.241
93.243
93.251
93.264**
93.268
93.270
93.279
93.283
93.301

93.305
93.319
93.323

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

SPECIAL PROGRAMS FOR THE AGING-TITLE III, PART D-DISEASE
PREVENTION AND HEALTH PROMOTION SERVICES
SPECIAL PROGRAMS FOR THE AGING-TITLE IV AND TITLE II DISCRETIONARY PROJECTS
ALZHEIMER'S DISEASE DEMONSTRATION GRANTS TO STATES
NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E
PUBLIC HEALTH EMERGENCY PREPAREDNESS
ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE
MEDICARE ENROLLMENT ASSISTANCE PROGRAM
BIRTH DEFECTS AND DEVELOPMENTAL DISABILITIES - PREVENTION
AND SURVEILLANCE
HOSPITAL PREPAREDNESS PROGRAM (HPP) AND PUBLIC HEALTH
EMERGENCY PREPAREDNESS (PHEP) ALIGNED COOPERATIVE
AGREEMENTS
COOPERATIVE AGREEMENTS TO PROMOTE ADOLESCENT HEALTH
THROUGH SCHOOL-BASED HIV/STD PREVENTION AND SCHOOL-BASED
SURVEILLANCE
GUARDIANSHIP ASSISTANCE
AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY
EDUCATION PROGRAM
WELL-INTEGRATED SCREENING AND EVALUATION FOR WOMEN
ACROSS THE NATION
FOOD AND DRUG ADMINISTRATION-RESEARCH
MATERNAL AND CHILD HEALTH FEDERAL CONSOLIDATED PROGRAMS
PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR
TUBERCULOSIS CONTROL PROGRAMS
EMERGENCY MEDICAL SERVICES FOR CHILDREN
COOPERATIVE AGREEMENTS TO STATES/TERRITORIES FOR THE
COORDINATION AND DEVELOPMENT OF PRIMARY CARE OFFICES
CENTERS FOR RESEARCH AND DEMONSTRATION FOR HEALTH
PROMOTION AND DISEASE PREVENTION
INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND
COMMUNITY BASED PROGRAMS
PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS
(PATH)
GRANTS TO STATES FOR LOAN REPAYMENT PROGRAM
FAMILY PLANNING SERVICES
TRAUMATIC BRAIN INJURY STATE DEMONSTRATION GRANT PROGRAM
TITLE V STATE SEXUAL RISK AVOIDANCE EDUCATION (TITLE V STATE
SRAE) PROGRAM
GRANTS TO STATES TO SUPPORT ORAL HEALTH WORKFORCE
ACTIVITIES
STATE RURAL HOSPITAL FLEXIBILITY PROGRAM
SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF
REGIONAL AND NATIONAL SIGNIFICANCE
UNIVERSAL NEWBORN HEARING SCREENING
NURSING FACULTY LOAN PROGRAM (NFLP)
IMMUNIZATION COOPERATIVE AGREEMENTS
VIRAL HEPATITIS PREVENTION AND CONTROL
DRUG ABUSE AND ADDICTION RESEARCH PROGRAMS
CENTERS FOR DISEASE CONTROL AND PREVENTION_INVESTIGATIONS
AND TECHNICAL ASSISTANCE
SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM
PPHF 2018: OFFICE OF SMOKING AND HEALTH - NATIONAL STATE
BASED TOBACCO CONTROL PROGRAMS - FINANCED IN PART BY 2018
PREVENTION AND PUBLIC HEALTH FUNDS (PPHF)
OUTREACH PROGRAMS TO REDUCE THE PREVALENCE OF OBESITY IN
HIGH RISK RURAL AREAS
EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS
DISEASES (ELC)

19

$23,245

$97,982

$121,227

$49,345
$48,516
$57,516
$12,236
$71,060
$45

$110,567
$116,000
$869,620
$60,000
$0
$238,772

$159,912
$164,516
$927,136
$72,236
$71,060
$238,817

$67,831

$190,150

$257,981

$2,542,469

$4,133,310

$6,675,779

$48,191
$1,236,487

$3,546
$0

$51,737
$1,236,487

$14,720

$187,328

$202,048

$391,001
$976,023

$146,612
$0

$537,613
$976,023

$99,702

$105,309

$205,011

$144,920
$107,348

$0
$29,497

$144,920
$136,845

$224,749

$45,000

$269,749

$10,172

$0

$10,172

$805,755

$912,611

$1,718,366

$2,824
$0
$2,386,669
$281,669

$230,663
$77,500
$0
$0

$233,487
$77,500
$2,386,669
$281,669

$5,771

$400,125

$405,896

$74,465
$120,382

$584,005
$330,639

$658,470
$451,021

$520,508
$68,210
$170,015
$547,055
$132,637
$14,412

$5,652,332
$28,291
$0
$135,083
$0
$0

$6,172,840
$96,501
$170,015
$682,138
$132,637
$14,412

$292,187
$0

$388,252
$107,697

$680,439
$107,697

$264,902

$88,572

$353,474

$428,863

$33,842

$462,705

$751,443

$0

$751,443

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

93.342**
93.359
93.364**

93.424

93.506
93.511

93.521

93.524

93.539
93.556
93.558
93.560
93.563
93.566
93.568
93.569
93.586
93.590
93.597
93.599
93.600
93.603
93.609
93.630
93.643
93.645
93.658
93.659
93.667
93.669
93.671
93.674
93.701***
93.713
93.732

93.733

93.735

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

HEALTH PROFESSIONS STUDENT LOANS, INCLUDING PRIMARY CARE
LOANS AND LOANS FOR DISADVANTAGED STUDENTS (HPSL/PCL/LDS)
NURSE EDUCATION, PRACTICE QUALITY AND RETENTION GRANTS
NURSING STUDENT LOANS (NSL)
NON-ACA/PPHF - BUILDING CAPACITY OF THE PUBLIC HEALTH SYSTEM
TO IMPROVE POPULATION HEALTH THROUGH NATIONAL NONPROFIT
ORGANIZATIONS
ACA NATIONWIDE PROGRAM FOR NATIONAL AND STATE
BACKGROUND CHECKS FOR DIRECT PATIENT ACCESS EMPLOYEES OF
LONG TERM CARE FACILITIES AND PROVIDERS
AFFORDABLE CARE ACT (ACA) GRANTS TO STATES FOR HEALTH
INSURANCE PREMIUM REVIEW
THE AFFORDABLE CARE ACT: BUILDING EPIDEMIOLOGY,
LABORATORY, AND HEALTH INFORMATION SYSTEMS CAPACITY IN THE
EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS
DISEASE (ELC) AND EMERGING INFECTIONS PROGRAM (EIP)
COOPERATIVE AGREEMENTS;PPHF
BUILDING CAPACITY OF THE PUBLIC HEALTH SYSTEM TO IMPROVE
POPULATION HEALTH THROUGH NATIONAL, NON-PROFIT
ORGANIZATIONS- FINANCED IN PART BY PREVENTION AND PUBLIC
HEALTH FUNDS (PPHF)
PPHF CAPACITY BUILDING ASSISTANCE TO STRENGTHEN PUBLIC
HEALTH IMMUNIZATION INFRASTRUCTURE AND PERFORMANCE
FINANCED IN PART BY PREVENTION AND PUBLIC HEALTH FUNDS
PROMOTING SAFE AND STABLE FAMILIES
TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF)
FAMILY SUPPORT PAYMENTS TO STATES-ASSISTANCE PAYMENTS
CHILD SUPPORT ENFORCEMENT
REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT
DESIGNEE ADMINISTERED PROGRAMS
LOW-INCOME HOME ENERGY ASSISTANCE
COMMUNITY SERVICES BLOCK GRANTS
STATE COURT IMPROVEMENT PROGRAM
COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS
GRANTS TO STATES FOR ACCESS AND VISITATION PROGRAMS
CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV)
HEAD START
ADOPTION AND LEGAL GUARDIANSHIP INCENTIVE PAYMENTS
THE AFFORDABLE CARE ACT - MEDICAID ADULT QUALITY GRANTS
DEVELOPMENTAL DISABILITIES BASIC SUPPORT AND ADVOCACY
GRANTS
CHILDREN'S JUSTICE GRANTS TO STATES
STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM
FOSTER CARE-TITLE IV-E
ADOPTION ASSISTANCE
SOCIAL SERVICES BLOCK GRANT
CHILD ABUSE AND NEGLECT STATE GRANTS
FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE
SHELTER AND SUPPORTIVE SERVICES
CHAFEE FOSTER CARE INDEPENDENCE PROGRAM
ARRA - TRANS-NIH RECOVERY ACT RESEARCH SUPPORT (NOTE 3)
ARRA - CHILD CARE AND DEVELOPMENT BLOCK GRANT
MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING
GRANTS
CAPACITY BUILDING ASSISTANCE TO STRENGTHEN PUBLIC HEALTH
IMMUNIZATION INFRASTRUCTURE AND PERFORMANCE - FINANCED IN
PART BY THE PREVENTION AND PUBLIC HEALTH FUND (PPHF)
STATE PUBLIC HEALTH APPROACHES FOR ENSURING QUITLINE
CAPACITY - FUNDED IN PART BY PREVENTION AND PUBLIC HEALTH
FUNDS (PPHF)

20

$7,791,144
$442,062
$739,915

$0
$0
$0

$7,791,144
$442,062
$739,915

$2,093

$84,469

$86,562

$1,526,936

$0

$1,526,936

$720

$0

$720

$228,038

$180,273

$408,311

$0

$5,708

$5,708

$573,801
$1,116,775
$92,121,332
($8,347)
$24,695,138

$604,091
$725,840
$9,644,993
$0
$0

$1,177,892
$1,842,615
$101,766,325
($8,347)
$24,695,138

$5,054
$19,864,755
$259,481
$278,755
$0
$117,870
$478,648
$14,737
$49,568
$304,247

$75,000
$7,700,299
$6,970,229
$0
$235,903
$0
$39,785
$60,482
$124,204
$0

$80,054
$27,565,054
$7,229,710
$278,755
$235,903
$117,870
$518,433
$75,219
$173,772
$304,247

$204,762
$133,031
$1,686,400
$52,935,362
$39,121,456
$19,967,868
$38,035

$378,780
$0
$0
$2,577,749
$116,508
$0
$105,615

$583,542
$133,031
$1,686,400
$55,513,111
$39,237,964
$19,967,868
$143,650

$0
$996,478
$15,550
($1,397)

$878,957
$713,103
$0
$0

$878,957
$1,709,581
$15,550
($1,397)

$24,058

$0

$24,058

$9,318

$0

$9,318

$36,643

$0

$36,643

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

93.745
93.753
93.757

93.758
93.767
93.779
93.788
93.791
93.800
93.815
93.817
93.859***
93.887
93.898
93.913
93.917
93.925**
93.940
93.944
93.945
93.946
93.958
93.959
93.965
93.977
93.982
93.994

93.044
93.045
93.053

93.505
93.870

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

PPHF: HEALTH CARE SURVEILLANCE/HEALTH STATISTICSSURVEILLANCE PROGRAM ANNOUNCEMENT: BEHAVIORAL RISK
FACTOR SURVEILLANCE SYSTEM FINANCED IN PART BY PREVENTION
AND PUBLIC HEALTH FUNDS (PPHF)
CHILD LEAD POISONING PREVENTION SURVEILLANCE FINANCED IN
PART BY PREVENTION AND PUBLIC HEALTH (PPHF) PROGRAM
STATE AND LOCAL PUBLIC HEALTH ACTIONS TO PREVENT OBESITY,
DIABETES, HEART DISEASE, AND STROKE (PPHF)
PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT FUNDED
SOLELY WITH PREVENTION AND PUBLIC HEALTH FUNDS (PPHF)
CHILDREN'S HEALTH INSURANCE PROGRAM
CENTERS FOR MEDICARE AND MEDICAID SERVICES (CMS) RESEARCH,
DEMONSTRATIONS AND EVALUATIONS
OPIOID STR
MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION
ORGANIZED APPROACHES TO INCREASE COLORECTAL CANCER
SCREENING
DOMESTIC EBOLA SUPPLEMENT TO THE EPIDEMIOLOGY AND
LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC)
HOSPITAL PREPAREDNESS PROGRAM (HPP) EBOLA PREPAREDNESS
AND RESPONSE ACTIVITIES
BIOMEDICAL RESEARCH AND RESEARCH TRAINING (NOTE 3)
HEALTH CARE AND OTHER FACILITIES
CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE,
TERRITORIAL AND TRIBAL ORGANIZATIONS
GRANTS TO STATES FOR OPERATION OF STATE OFFICES OF RURAL
HEALTH
HIV CARE FORMULA GRANTS
SCHOLARSHIPS FOR HEALTH PROFESSIONS STUDENTS FROM
DISADVANTAGED BACKGROUNDS
HIV PREVENTION ACTIVITIES-HEALTH DEPARTMENT BASED
HUMAN IMMUNODEFICIENCY VIRUS (HIV)/ACQUIRED
IMMUNODEFICIENCY VIRUS SYNDROME (AIDS) SURVEILLANCE
ASSISTANCE PROGRAMS FOR CHRONIC DISEASE PREVENTION AND
CONTROL
COOPERATIVE AGREEMENTS TO SUPPORT STATE-BASED SAFE
MOTHERHOOD AND INFANT HEALTH INITIATIVE PROGRAMS
BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES
BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE
ABUSE
COAL MINERS RESPIRATORY IMPAIRMENT TREATMENT CLINICS AND
SERVICES
SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND
CONTROL GRANTS
MENTAL HEALTH DISASTER ASSISTANCE AND EMERGENCY MENTAL
HEALTH
MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE
STATES
AGING CLUSTER
SPECIAL PROGRAMS FOR THE AGING-TITLE III, PART B-GRANTS FOR
SUPPORTIVE SERVICES AND SENIOR CENTERS
SPECIAL PROGRAMS FOR THE AGING-TITLE III, PART C-NUTRITION
SERVICES
NUTRITION SERVICES INCENTIVE PROGRAM
TOTAL AGING CLUSTER
MATERNAL, INFANT, AND EARLY CHILDHOOD HOME VISITING
CLUSTER
AFFORDABLE CARE ACT (ACA) - MATERNAL, INFANT, AND EARLY
CHILDHOOD HOME VISITING PROGRAM
MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT
PROGRAM
TOTAL MATERNAL, INFANT, AND EARLY CHILDHOOD HOME VISITING
CLUSTER

21

$195,472

$0

$195,472

$164,058

$0

$164,058

$226,772

$211,375

$438,147

$654,051
$68,660,487

$437,661
$10,190

$1,091,712
$68,670,677

$79,596
$18,119
$1,890,793

$314,495
$2,379,689
$1,222,625

$394,091
$2,397,808
$3,113,418

$484,781

$73,700

$558,481

$107,541

$114,177

$221,718

$0
$849,603
$828

$339,337
$0
$0

$339,337
$849,603
$828

$1,516,889

$268,216

$1,785,105

$109,264
$3,490,226

$0
$1,720,132

$109,264
$5,210,358

$617,837
$628,127

$0
$5,310

$617,837
$633,437

$169,449

$0

$169,449

$367,264

$64,369

$431,633

$89,957
$251,104

$0
$2,499,830

$89,957
$2,750,934

$366,311

$7,759,202

$8,125,513

$134,415

$1,085,482

$1,219,897

$388,846

$0

$388,846

$0

$545,600

$545,600

$3,096,093

$1,827,021

$4,923,114

$109,951

$2,414,145

$2,524,096

$246,711
$0
$356,662

$4,556,918
$1,414,805
$8,385,868

$4,803,629
$1,414,805
$8,742,530

$17,842

$2,161,787

$2,179,629

$394,576

$4,938,084

$5,332,660

$412,418

$7,099,871

$7,512,289

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

93.575

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

CCDF CLUSTER
CHILD CARE AND DEVELOPMENT BLOCK GRANT
CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE
AND DEVELOPMENT FUND
TOTAL CCDF CLUSTER

$10,940,108

$9,491,830

$20,431,938

$18,014,471
$28,954,579

$2,461,728
$11,953,558

$20,476,199
$40,908,137

$776,426

$0

$776,426

$3,953,499
$3,044,705,576
$5,066,667
$3,054,502,168

$0
$1,890,893
$0
$1,890,893

$3,953,499
$3,046,596,469
$5,066,667
$3,056,393,061

($12)
$141,501
$11,960
$45
$224,218
$30,478
$21,197
($58)
$382,230
$43,453

$0
$0
$0
$0
$0
$0
$0
$0
$173,429
$0

($12)
$141,501
$11,960
$45
$224,218
$30,478
$21,197
($58)
$555,659
$43,453

$19,965
$47,359

$0
$0

$19,965
$47,359

$60,321
$1,025
$1

$0
$0
$0

$60,321
$1,025
$1

$20,345
$3,448,638,105

$0
$96,943,811

$20,345
$3,545,581,916

CORPORATION FOR NATIONAL AND COMMUNITY SERVICE
94.003
STATE COMMISSIONS
94.006
AMERICORPS
94.009
TRAINING AND TECHNICAL ASSISTANCE
94.013
VOLUNTEERS IN SERVICE TO AMERICA
94.021
VOLUNTEER GENERATION FUND
TOTAL CORPORATION FOR NATIONAL AND COMMUNITY SERVICE

$273,064
($1,640)
$68,805
$45,313
$18,013
$403,555

$0
$3,587,666
$0
$0
$2,943
$3,590,609

$273,064
$3,586,026
$68,805
$45,313
$20,956
$3,994,164

EXECUTIVE OFFICE OF THE PRESIDENT
95.001
HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM (NOTE 3)
EXECUTIVE OFFICE OF THE PRESIDENT

$767,097
$767,097

$0
$0

$767,097
$767,097

$18,329,033

$0

$18,329,033

$0
$4,378
$68,738
$18,402,149

$103,100
$0
$0
$103,100

$103,100
$4,378
$68,738
$18,505,249

93.596

93.775
93.777
93.778
ARRA 93.778

MEDICAID CLUSTER
STATE MEDICAID FRAUD CONTROL UNITS
STATE SURVEY AND CERTIFICATION OF HEALTH CARE PROVIDERS
AND SUPPLIERS (TITLE XVIII) MEDICARE
MEDICAL ASSISTANCE PROGRAM
ARRA - MEDICAL ASSISTANCE PROGRAM
TOTAL MEDICAID CLUSTER

93.U15
93.U16
93.U17
93.U18
93.U19
93.U20
93.U21
93.U22
93.U23
93.U24

WAIVED LABS
CLINICAL LABORATORY IMPROVEMENT AMENDMENTS
PTD BUSINESS CASE (IPA ASSIGNMENT)
NTDI EY2010
VITAL STATISTICS COOP PROGRAM
FOOD INSPECTIONS
MAMMOGRAPHY QUALITY ACT
DEATH RECORDS
TOBACCO WORKPLAN
MEDICAID 1115 SUD WAIVER EVALUATION
RESEARCH AND ANALYSIS OF POTENTIAL SECTION 1115 WAIVER
93.U25
OPTIONS
93.U26
DHHR HEALTH PROMOTION AND CHRONIC DISEASE STRATEGIC
PLANNING AND EVALUATION COORDINATION INDEPENDENT
93.U27
VERIFICATION AND VALIDATION
93.U28
FEDERAL FOOD, DRUG AND COSMETIC ACT
93.U29
NATIONAL HEALTH INFORMATION NETWORK II (NHIN2)
EVALUATION OF PERSONAL RESPONSIBILITY EDUCATION PROGRAM
93.U30
(PREP)
TOTAL DEPARTMENT OF HEALTH AND HUMAN SERVICES

SOCIAL SECURITY ADMINISTRATION
SOCIAL SECURITY-DISABILITY INSURANCE (DI) AND DISABILITY
96.001
INSURANCE/SSI CLUSTER
SOCIAL SECURITY - WORK INCENTIVES PLANNING AND ASSISTANCE
96.008
PROGRAM
96.U31
DEATH RECORDS
96.U32
ENUMERATION AT BIRTH
TOTAL SOCIAL SECURITY ADMINISTRATION

22

 STATE OF WEST VIRGINIA
SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FEDERAL GRANTOR LISTING
FOR THE YEAR ENDING JUNE 30, 2018

FEDERAL CFDA / GRANT/
CONTRACT NUMBER

STATE OF WEST
TOTAL
TOTAL
VIRGINIA
SUBRECIPENT
FEDERAL
EXPENDITURES EXPENDITURES EXPENDITURES

NAME OF PROGRAM

DEPARTMENT OF HOMELAND SECURITY
97.012
BOATING SAFETY FINANCIAL ASSISTANCE
COMMUNITY ASSISTANCE PROGRAM STATE SUPPORT SERVICES
97.023
ELEMENT (CAP-SSSE)
97.032
CRISIS COUNSELING
DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY
97.036
DECLARED DISASTERS)
97.039
HAZARD MITIGATION GRANT
97.041
NATIONAL DAM SAFETY PROGRAM
97.042
EMERGENCY MANAGEMENT PERFORMANCE GRANTS
97.044
ASSISTANCE TO FIREFIGHTERS GRANT
97.045
COOPERATING TECHNICAL PARTNERS
97.047
PRE-DISASTER MITIGATION
97.056
PORT SECURITY GRANT PROGRAM
97.067
HOMELAND SECURITY GRANT PROGRAM
97.088
DISASTER ASSISTANCE PROJECTS
TOTAL DEPARTMENT OF HOMELAND SECURITY
TOTAL EXPENDITURES OF FEDERAL AWARDS

$580,073

$0

$580,073

$66,429
$0

$0
($98,192)

$66,429
($98,192)

$17,294,818
$593,036
$68,036
$1,826,127
$501,354
$52,870
$195,868
$200,631
$583,441
$47,548
$22,010,231

$15,164,213
$4,735,620
$0
$3,245,967
$0
$2,549
$0
$0
$2,811,462
$2,070,684
$27,932,303

$32,459,031
$5,328,656
$68,036
$5,072,094
$501,354
$55,419
$195,868
$200,631
$3,394,903
$2,118,232
$49,942,534

$5,626,900,646

$582,027,374

$6,208,928,020

* HIGHWAY PLANNING AND CONSTRUCTION CLUSTER, TOTAL STATE OF WEST VIRGINIA EXPENDITURES $386,726,259
TOTAL SUBRECIPIENT EXPENDITURES $4,701,138 AND TOTAL FEDERAL EXPENDITURES $391,427,397.
** STUDENT FINANCIAL ASSISTANCE CLUSTER, TOTAL STATE OF WEST VIRGINIA EXPENDITURES $627,234,851
TOTAL SUBRECIPIENT EXPENDITURES $0 AND TOTAL FEDERAL EXPENDITURES $627,234,851.
*** RESEARCH AND DEVELOPMENT CLUSTER, TOTAL STATE OF WEST VIRGINIA EXPENDITURES $5,988,320
TOTAL SUBRECIPIENT EXPENDITURES $3,729,423, AND TOTAL FEDERAL EXPENDITURES $9,717,743.
The accompanying notes are an integral part of this schedule.

23

 WEST VIRGINIA
STATE OF WEST VIRGINIA
NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
NOTE 1.

BASIS OF ACCOUNTING
The Schedule of Expenditures of Federal Awards (the Schedule) has been
prepared on the cash basis of accounting. The federal awards are listed in
the Schedule under the federal agency supplying the award. The individual
Catalog of Federal Domestic Assistance (CFDA) numbers are listed first,
then clusters, and then federal contract numbers. Federal contract numbers
are used if the CFDA number is not available.
The Schedule includes noncash items such as Food Stamps (CFDA number
10.551), State Administrative Expense for Child Nutrition (CFDA number
10.560), and Donation of Federal Surplus Personal Property (CFDA number
39.003). All items are valued based on amounts as established by the
federal grantor agency. The Schedule also includes Federal Direct Student
Loans (CFDA number 84.268) that are made directly to individual students.

NOTE 2.

REPORTING ENTITY
The Schedule includes various departments, agencies, boards and
commissions governed by the legislature, judiciary and/or constitutional
officers of the State of West Virginia (the State). The reporting entity also
includes the State’s institutions of public higher education. Certain
institutions of higher education within the State maintain separate
research corporations. These corporations receive various federal awards
for research and development and other programs. Each of the research
corporations has a separate audit performed in accordance with the
Uniform Guidance, and accordingly, a separate submission has been made
(see Note 8).
The Schedule does not include federal funds received and expended by
certain independent authorities and other organizations included in the
reporting entity under the criteria of the Governmental Accounting
Standards Board, as described in Note 1 to the State’s basic financial
statements published in the Comprehensive Annual Financial Report for
the fiscal year ended June 30, 2018. The West Virginia Housing
Development Fund and the West Virginia Drinking Water Treatment
Revolving Loan Fund, which is a discretely presented component unit and
a proprietary fund, respectively, elected to have their own single audit;
therefore, their expenditures of federal awards are excluded from the
State’s schedule of expenditures of federal awards. This component unit and
proprietary fund are required to submit their own single audit report to the
federal audit clearinghouse (see Note 8).

24

 SINGLE AUDIT
STATE OF WEST VIRGINIA
NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
NOTE 3.

INDIRECT/PASS-THROUGH FEDERAL FUNDS
The United States Office of Drug Control Policy provides funds to the
Laurel County Fiscal Court of London, Kentucky. A portion of these funds
are passed through from the Fiscal Court to the State with identifying
numbers HDTA17 and HDTA18.
The West Virginia Research Corporation passed funds to the West Virginia
School of Osteopathic Medicine for CFDA Number 93.859 with passthrough entity identifying numbers 12-303-WVSOM-4 and 12-303WVSOM-5, and also to Shepherd University for CFDA Number 43.008
with pass-through identifying number 91-175C-SU and for CFDA Number
93.859 with pass-through identifying numbers 01-054B-SU6 and 01-054BSU-7. The West Virginia Research Corporation also passed funds to the
West Virginia Geological and Economic Survey for CFDA Number 81.087
with pass-through identifying number 17-463-WVGES.
The Marshall University Research Corporation passed funds to the West
Virginia School of Osteopathic Medicine for CFDA Number 93.859 with
pass-through identifying numbers P1800873 and P1801984.
The Battelle Research Institute and Tetra Tech passed funds to the West
Virginia Geological and Economic Survey for CFDA Number 81.089 with
identifying numbers 354860, 3377572, 507700, and 1137982.
The Emmes Corporation pass funds to West Virginia University for CFDA
Number 93.701 with identifying number 1 U01 NS062835-01A1.

NOTE 4.

UNEMPLOYMENT INSURANCE PROGRAM (UI) (CFDA NUMBER
17.225)
The U.S. Department of Labor, in consultation with the Office of
Management and Budget officials, has determined that for the purpose of
audits and reporting under the Uniform Guidance, state UI funds as well
as federal funds should be considered federal awards for determining Type
A programs. The State receives federal funds for administrative purposes.
State unemployment taxes must be deposited to a state account in the
Federal Unemployment Trust Fund, used only to pay benefits under the
federally approved state law. State UI funds as well as federal funds are
included on the Schedule.

25

 WEST VIRGINIA
STATE OF WEST VIRGINIA
NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018

The following schedule provides a breakdown of the state and federal
portions of the total expended under CFDA number 17.225:
Beginning Balance
July 1, 2017
As Adjusted
State UI Funds

NOTE 5.

Expenditures

Ending Balance
June 30, 2018

$ (319,385)

$346,976,395

$347,144,413

$ (487,403)

428,761

14,144,314

13,718,766

854,309

109,376

$361,120,709

$360,863,179

Federal UI Funds
Total

Receipts

$

$

366,906

LOANS OUTSTANDING
Loans outstanding as of June 30, 2018, with continuing compliance
requirements, are as follows:
CFDA
Number

Name of Program

Ending Balance

84.038

Federal Perkins Loan (FPL) – Federal Capital Contribution

93.264

Nurse Faculty Loan Program (NFLP)

93.342

Health Professions Student Loans, Including Primary Care
Loans and Loans for Disadvantaged Students (HPSL/PCL/LDS)

93.364

Nursing Student Loans (NSL)

163,997
6,951,878
652,380

Total Loans Outstanding

NOTE 6.

$38,632,545

$46,400,800

APPROVED PROJECT WORKSHEETS
The State incurred eligible expenditures in FY 2017 and the Federal
Emergency Management Agency (FEMA) approved the State’s project
worksheets in FY 2018. The State recorded the eligible expenditures of
$2,153,175 in CFDA 97.036 on this year’s SEFA.

NOTE 7.

INDIRECT COST RATE
Per Uniform Guidance 2 CFR § 200.510(b)(6), auditees are required to
disclose whether or not they elect to use the 10 percent de minimis cost
rate that 2 CFR§ 200.414(f) allows for nonfederal entities that have never
received a negotiated indirect cost rate. The State does not elect to use the
10 percent de minimis cost rate.

26

 SINGLE AUDIT
STATE OF WEST VIRGINIA
NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
NOTE 8.

COMPONENT UNITS / PROPRIETARY FUND
The following is a summary of federal awards at the various component
units and a proprietary fund that have separate Uniform Guidance audits
and submissions. These awards have been excluded from the State’s
Schedule.
West Virginia University Research Corporation

$ 96,668,381

Marshall University Research Corporation
West Virginia State University Research and
Development Corporation

$ 17,229,934

West Virginia Housing Development Fund
West Virginia Drinking Water Treatment Revolving Loan
Fund

$ 186,054,123

27

$ 12,513,853

$

2,188,894

  CHED ULE 0F

FINDINGS
AND

QUES TI ONED
COSTS

 

STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

Section I. Summary of Auditor’s Results
Financial statements:
Type of report the auditors issued on whether the financial
statements audited were prepared in accordance with GAAP
(unmodified, qualified, adverse or disclaimer):

Unmodified, with reference to
other auditors

Internal control over financial reporting:
Material weakness(es) identified?

X

Significant deficiency(ies) identified?
Noncompliance material to financial statements noted?

Yes
Yes

X

No
None
reported

Yes

X

No

Federal awards:
Internal control over major federal programs:
Material weakness(es) identified?
Significant deficiency(ies) identified?
Type of auditors’ report issued on compliance for major federal
programs (unmodified, qualified, adverse or disclaimer):

Any audit findings disclosed that are required to be reported in
accordance with 2 CFR 200.516(a)?

28

X

Yes

X

Yes

No
None
reported

Unmodified for all major
programs except for the National
Guard Military Operations and
Maintenance (O&M) Projects;
Community Development Block
Grants/State’s Program and NonEntitlement Grants in Hawaii;
Student Financial Assistance
Cluster; Temporary Assistance
For Needy Families (TANF)
Cluster; Low-Income Home
Energy Assistance; and Adoption
Assistance, which were qualified
and the Disaster Grants – Public
Assistance (Presidentially
Declared Disasters), Hazard
Mitigation Grant (HMPG), and
Emergency Management
Performance Grants, which were
adverse

X

Yes

No

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

Identification of Major Federal Programs:
Audited by Ernst & Young:

CFDA Number(s)

Reportable
Findings

Name of Federal Program or Cluster

10.551/10.561

None

Supplemental Nutrition Assistance Program (SNAP) Cluster

12.401

2018–002, 003

National Guard Military Operations and Maintenance (O&M) Projects

14.228

2018–004, 005

Community Development Block Grants/State's Program and
Non-Entitlement Grants in Hawaii

15.252

None

Abandoned Mine Land Reclamation (AMLR) Program

20.205/20.219/
20.224/23.003

2018–006, 007,
008

Highway Planning and Construction Cluster

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

2018–009, 010,
011, 012,
013

Student Financial Assistance Cluster

84.010

None

Title I Grants to Local Educational Agencies

84.126

2018–014, 015,
016

Rehabilitation Services—Vocational Rehabilitation Grants to States

93.558

2018–017, 018,
019, 020

Temporary Assistance for Needy Families (TANF) Cluster

93.563

None

Child Support Enforcement

93.568

2018–017, 021

Low-Income Home Energy Assistance

93.575/93.596

2018–017, 022

Child Care and Development Fund (CCDF) Cluster

93.658

2018–017

Foster Care—Title IV-E

93.659

2018–017, 023

Adoption Assistance

93.767

2018–017

Children's Health Insurance Program (CHIP)

93.775/93.777/
*93.778 & ARRA

2018–017, 024

Medicaid Cluster

29

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

Identification of Major Federal Programs (continued):
Audited by Ernst & Young:
CFDA Number(s)

Reportable
Findings

Name of Federal Program or Cluster

97.036

2018–025, 026,
027, 028,
029

Disaster Grants – Public Assistance (Presidentially Declared Disasters)

97.039

2018–030, 031,
032, 033,
034

Hazard Mitigation Grant (HMGP)

97.042

2018–035, 036,
037, 038,
039, 040,
041, 042,
043, 044

Emergency Management Performance Grants

Audited by other auditors:
66.458

None

Capitalization Grants for Clean Water State Revolving Funds

Dollar threshold used to distinguish between Type A and B programs:
Auditee qualified as low-risk auditee

$

18,626,784
Yes

* CFDA number includes federally identifiable American Recovery and Reinvestment Act Funds.

30

X

No

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

Section II. Financial Statement Findings
Reference
Number
2018–001

Questioned
Costs
N/A

Findings
Financial Statement Close Process

Section III. Federal Award Findings and Questioned Costs
Reference
Number
2018–002

Questioned
Costs
$28,478

Period of Performance

2018–003

Program Income Monitoring

2018–004

Reporting

2018–005

Internal Controls Over Allowability and Procurement

2018–006

Federal Highways Administration Period of Performance

2018–007

Internal Controls Over Schedule of Expenditures and
Federal Awards

2018–008

Wage Rate Requirements

2018–009

Internal Controls Over Schedule of Expenditures of Federal
Awards

2018–010

Internal Controls Over Cash Management

N/A

2018–011

Special Tests and Provisions – Disbursements to or on
Behalf of Students

N/A

2018–012

Special Tests and Provisions – Enrollment Reporting

N/A

2018–013

Special Tests and Provisions – Internal Controls Over
Borrower Data Transmission and Reconciliation

N/A

2018–014

Eligibility

N/A

2018–015

Reporting

N/A

2018–016

Special Tests and provisions – Completion of Individual
Plan for Employment (IPEs)

Unknown

2018–017

DHHR Information System and Related Business Process
Controls

N/A

2018–018

Reporting

2018–019

Special Tests and Provisions – Internal Controls Over Child
Support Non-cooperation, Penalty for Refusal to Work,
and Adult Custodial Parent of Child Under Six When
Child Care Not Available

2018–020

Special Tests and Provisions – Child Support NonCooperation

2018–021

Allowability and Eligibility

2018–022

Special Tests and Provisions – Fraud Detection and
Repayment Controls

Findings

$376,693
N/A
$880,658
$3,664,218
N/A
$2,877,461
N/A

Unknown
N/A

Unknown
$1,930

31

N/A

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

Section III. Federal Award Findings and Questioned Costs
(continued):
Reference
Number
2018–023

Questioned
Costs
$2,431

Findings
Eligibility Documentation

2018–024

Activities Allowed or Unallowed and Allowable Costs/Cost
Principles

$0.26

2018–025

Internal Controls Over Reporting

N/A

2018–026

Internal Control Over Allowability

N/A

2018–027

Cash Management

2018–028

Subrecipient Cash Management

2018–029

Subrecipient Monitoring

2018–030

Subrecipient Cash Management

2018–031

Subrecipient Eligibility

2018–032

Matching

$104,117

2018–033

Reporting

$143,369

2018–034

Subrecipient Monitoring

Unknown

2018–035

Schedule of Expenditures of Federal Awards

2018–036

Allowability

2018–037

Subrecipient Cash Management

2018–038

Eligibility for Subrecipients

$901,411

2018–039

Earmarking

Unknown

2018–040

Matching

$40,203

2018–041

Reporting

$1,914

2018–042

Subrecipient Monitoring

2018–043

Special Tests and Provisions – Closeout Reporting
Requirements

N/A

2018–044

Special Tests and Provisions – Training and Exercise Plan
Requirements

N/A

Unknown
N/A
Unknown
N/A
$1,578,214

N/A
$922,168
N/A

Unknown

32

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–001 FINANCIAL STATEMENT CLOSE PROCESS
Federal Program Information:

Criteria:

State Agency and Department Name
Department of Administration Financial Accounting and Reporting Section
(FARS)

Critical elements of an entity’s internal control is its ability to record, process, and summarize
accounting transactions in a timely manner and to prepare financial reports that give a true
and accurate assessment of the entity’s financial status. Timely and accurate financial
information is crucial to effective decision-making by management.
Further, a fundamental concept of effective internal control is supervision and review of
general ledger activities, including journal entries.

Condition:

Significant accounting adjustments were identified as a result of our audit procedures in the
following accounts: Medicaid drug rebate receivable, Medicaid liability, and the related
expense accounts related to the government-wide and the general fund financial statements.
Reclassification adjustments were identified related to fund balance on the government-wide
statement of net position. Significant adjustments were identified related to the
implementation of GASB 75, Accounting and Financial Reporting for Post-Employment
Benefits other than Pensions.

Questioned Costs:

N/A

Context:

Management recorded significant audit adjustments in order to prepare accurate financial
statements as of June 30, 2018 and for the year then ended.

Cause:

Management indicated that the deficiency noted above is due to the timing of obtaining
information from the respective agencies.

Effect:

Management recorded significant audit adjustments in order to prepare accurate financial
statements as of June 30, 2018, and for the year then ended.

Recommendation:

Management should work closely with the respective agencies to understand the information
provided and determine the accounting implications. In addition, management should
evaluate new GASB pronouncements earlier and determine their impact on the financial
statements.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

33

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–002 PERIOD OF PERFORMANCE
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Defense
National Guard Military Operations and Maintenance
(O&M) Projects

CFDA #
12.401

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 nonFederal 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).
OMB Circular A-133 section 300b states that the DHHR is responsible for maintaining
“internal control over Federal programs that provides reasonable assurance that management
is managing Federal awards in compliance with laws, regulations, and the provisions of
contracts or grant agreements that could have a material effect on each of its Federal
programs.”
2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only
allowable costs incurred during the period of performance.”
2 CFR 200.343(b) requires that “unless the Federal awarding agency or pass-through entity
authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the
Federal award not later than 90 calendar days after the end date of the period of performance
as specified in the terms and conditions of the Federal award.”
A-102 Common Rule (§____.23) states that “where a funding period is specified, a grantee
may charge to the award only costs resulting from obligations of the funding period unless
carryover of unobligated balances is permitted, in which case the carryover balances may be
charged for costs resulting from obligations of the subsequent funding period.”

Condition:

Three of the sixteen transactions tested from grants with performance period beginning dates
during the audit period were incorrectly charged to the grant. Expenditures were incurred
prior to the period of performance beginning. One of the twenty-one transactions tested from
grants with performance period ending dates during the audit period were not liquidated
within the 90-day period.

Questioned Costs:

$28,478 – CFDA #12.401; $9,163 related to Grant Award W912L8-18-2-1001 and $19,315
related to Grant Award W912L8-18-2-1002

Context:

Total federal expenditures for National Guard Military Operations and Maintenance (O&M)
Projects program were $25,604,542 for the year ended June 30, 2018. The four transactions
incurred outside the period of performance or the liquidation period represent $28,478 of total
expenditures tested for period of performance and liquidation of $152,124.

Cause:

The National Guard Military Operations and Maintenance (O&M) does not have adequate
internal controls and policies and procedures in place to ensure that expenditures are being
incurred within the period of performance and liquidated within the period of liquidation.

34

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–002 PERIOD OF PERFORMANCE
(continued)
Effect:

O&M is not in compliance with federal statutes, regulations, and the terms of the conditions
of the federal award. Expenditures were charged to the grant that are not allowable.

Recommendation:

We recommend that the National Guard Military Operations and Maintenance (O&M)
implement internal controls and policies and procedures to ensure that expenditures are
incurred within the period of performance and liquidated within 90 days after the period of
performance.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

35

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–003 PROGRAM INCOME MONITORING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Defense
National Guard Military Operations and Maintenance
(O&M) Projects

CFDA #
12.401

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 nonFederal 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 200.307(e)(1) states that “ordinarily program income must be deducted from total
allowable costs to determine the net allowable costs. Program income must be used for
current costs unless the Federal awarding agency authorizes otherwise. Program income that
the non-Federal entity did not anticipate at the time of the Federal award must be used to
reduce the Federal award and non-Federal entity contributions rather than to increase the
funds committed to the project.”

Condition:

According to a monitoring report from the Office of the United States Property and Fiscal
Officer for West Virginia, the West Virginia Army National Guard (WVARNG) did not
track, report, or remit program income earned through the operation of the Full Time Dining
Operations Cooperative Agreement (the Agreement) in accordance with the Agreement and
applicable regulations.

Questioned Costs:

$376,693 – CFDA #12.401 related to Grant Award W9128L8-18-2-1008

Context:

The program income related to the operation of the Full Time Dining Operation Cooperative
Agreement was $376,693 for fiscal 2018. Total federal expenditures for National Guard
Military Operations and Maintenance (O&M) Projects program were $25,604,542 for the
year ended June 30, 2018.

Cause:

WVARNG does not have adequate internal controls and policies and procedures in place to
ensure that program income is being tracked, reported and used to offset future program
draws.

Effect:

WVARNG is not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award. Program income earned and not identified timely and
returned to the federal program.

Recommendation:

We recommend that WVARNG implement internal controls and policies and procedures to
ensure that program income was being tracked, reported, and remitted back to the federal
government as required in a timely manner.

36

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–003 PROGRAM INCOME MONITORING
(continued)
Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

37

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–004 REPORTING
Federal Program Information:

Criteria:

Federal Agency and Program Name
CFDA #
U.S. Department of Housing and Urban Development
Community Development Block Grants/State’s Program
and Non-Entitlement Grants in Hawaii
14.228
Grant Award B14DC540001
Grant Award B15DC540001
Grant Award B16DC540001
Grant Award B17DC540001
Grant Award B16DL540001

CFR 200.303 requires that the West Virginia Community Advancement and Development
Office (WV CAD) 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
Per 29 CFR section 97.20, “Grantees and subgrantees must maintain records which
adequately identify the source and application of funds provided for financially-assisted
activities. These records must contain information pertaining to grant or subgrant awards and
authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures,
and income.”

Condition:

Management of the West Virginia Community Advancement and Development Office (WV
CAD) prepared and submitted the Consolidated Annual Performance and Evaluation Report
(CAPER) and the HUD 60002 Section 3 Summary Report without going through an
appropriate review and approval process. We identified a difference between the supporting
documentation and the Amount Expended During the Program Year for CDBG in the
CAPER, Section CR-15-Resources and Investments 91.520(a). CDBG reported $9,588,462
and provided supporting documentation for $14,659,530.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Community Development Block Grants program were
$16,070,814, for the year ended June 30, 2018.

Cause:

WV CAD does not have adequate internal controls policies and procedures in place over the
reporting process.

Effect:

WV CAD is not in compliance with the federal rules and regulations regarding reporting.
Reports could be filed with errors or lack of supporting documentation and not be identified
by management.

38

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–004 REPORTING
(continued)
Recommendation:

We recommend that WV CAD implement more robust internal controls over the report
submission process. At a minimum, such controls should include a documented review and
approval process that ensures reported amounts agree with supporting documentation. We
recommend that the review be performed by an individual independent of the data entry
process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

39

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–005 INTERNAL CONTROLS OVER ALLOWABILITY AND PROCUREMENT
Federal Program Information:

Criteria:

Federal Agency and Program Name
CFDA #
U.S. Department of Housing and Urban Development
Community Development Block Grants/State’s Program
and Non-Entitlement Grants in Hawaii
14.228
Grant Award B14DC540001
Grant Award B15DC540001
Grant Award B16DC540001
Grant Award B17DC540001
Grant Award B16DL540001

CFR 200.303 requires that the West Virginia Community Advancement and Development
Office (WV CAD) 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 200.320(b) requires that “Procurement by small purchase procedures. Small purchase
procedures are those relatively simple and informal procurement methods for securing
services, supplies, or other property that do not cost more than the Simplified Acquisition
Threshold. If small purchase procedures are used, price or rate quotations must be obtained
from an adequate number of qualified sources.”

Condition:

During our testing of 60 expenditures for allowability, we noted that for 1 of the 60 payments
there was a lack of supporting documentation for price or rate quotations from qualified
sources resulting in an invalid task order. Additionally, WV CAD is required to file HUD
Form 7015.15 and receive back HUD Form 7015.16 prior to entering into any contracts.
Seven contracts were entered into committing Disaster Recovery funding prior to the date
upon which WV CAD received HUD Form 7015.16, Authority to use Grant Funds.

Questioned Costs:

$880,658 – CFDA #14.228 related to Grant Award B16DL540001

Context:

Total federal expenditures for the Community Development Block Grants program were
$16,070,814, of which total nonsubrecipient federal expenditures were $1,991,044, for the
year ended June 30, 2018.

Cause:

WV CAD does not have adequate internal controls and policies and procedures in place to
ensure that payments are made only when a valid task order is in place.

Effect:

Task orders may not be properly approved resulting in disallowed costs.

40

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–005 INTERNAL CONTROLS OVER ALLOWABILITY AND PROCUREMENT
(continued)
Recommendation:

We recommend that WV CAD implement internal controls over the disbursement process to
ensure that all task orders and other supporting documentation are obtained prior to payments
being made. Additionally, they should ensure that all task orders are valid.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

41

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–006 FEDERAL HIGHWAYS ADMINISTRATION PERIOD OF PERFORMANCE
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Transportation
Highways Planning and Construction Cluster

CFDA #
20.205/20.219/
20.224/23.003

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 nonFederal 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 200.309 requires that “a non-Federal entity may charge to the Federal award only
allowable costs incurred during the period of performance and any costs incurred before the
Federal awarding agency or pass-through entity made the Federal award that were authorized
by the Federal awarding agency or pass-through entity.”

Condition:

The West Virginia Division of Highways “Division” had project agreements that had no end
dates in the award agreements. Thus, it cannot be determined whether costs incurred pursuant
to those agreements were incurred within the period of performance.

Questioned Costs:

$3,664,218 – CFDA #20.205

Context:

Total federal expenditures for the Highways Planning and Construction Cluster were
$391,427,397 for the year ended June 30, 2018. Management identified program agreements
from fiscal 2015 through fiscal 2018 that did not have end dates. Total federal expenditures
related to project agreements without end dates for fiscal year 2018 was $3,664,218.

Cause:

The Division does not have adequate internal controls and policies and procedures in place
to ensure that all projects had end dates.

Effect:

The Division was not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award including period of performance requirements.

Recommendation:

We recommend that the Division implement internal controls and policies and procedures to
ensure that all project agreements have end dates and that no additional costs are incurred
after such dates.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

42

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–007 INTERNAL CONTROLS OVER SCHEDULE OF EXPENDITURES AND FEDERAL AWARDS
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Transportation
Highways Planning and Construction Cluster

CFDA #
20.205/20.219/
20.224/23.003

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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 is not reconciling wvOASIS expenditures to the underlying expenditures in the
detail system, REMIS. The West Virginia Division of Highways (Division) is currently using
two systems for financial reporting. The Advanced Solution with Integrated Systems
(wvOASIS) is the State’s ERP accounting system and is used by the Division to process
revenue and expenditure transactions of $391,427,397. The Remote Entry Management
Information System (REMIS) is used by the Division for project accounting which includes
job cost, payroll, and billing. REMIS is also used by the Division for the preparation of the
schedule of expenditures and federal awards.

Questioned Costs:

N/A

Context:

Total expenditures for the Highways Planning and Construction Cluster were $391,427,397
for the year ended June 30, 2018.

Cause:

The Division has not established internal controls or policies or procedures to reconcile the
expenditures reported in the two systems for the year ended June 30, 2018.

Effect:

Differences between the two systems could exist and may not be timely detected or corrected
leading to misstatements in the schedule of expenditures of federal awards.

Recommendation:

We recommend that reconciliations between the two systems be performed, reviewed and
approved to ensure completeness and accuracy of the schedule of expenditures of federal
awards.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

43

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–008 WAGE RATE REQUIREMENTS
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Transportation
Highways Planning and Construction Cluster

CFDA #
20.205/20.219/
20.224/23.003

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 nonFederal 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).
40 USC 3141-3144 requires that all laborers and mechanics employed by contractors or
subcontractors to work on construction contracts in excess of $2,000 financed by Federal
assistance funds must be paid wages not less than those established for the locality of the
project (prevailing wage rates) by the Department of Labor (DOL). The contractor or
subcontractor must submit the required certified payrolls.

Condition:

For two of the twenty-five projects selected for testing, there was no documentation that the
certified payrolls were received or reviewed by an individual at the West Virginia Division
of Highways (the Division).

Questioned Costs:

$2,877,461 – CFDA #20.205

Context:

Total federal payroll expenditures and total federal expenditures for the Highways Planning
and Construction Cluster program were $19,437,813 and $391,427,397, respectively, for the
year ended June 30, 2018. The two projects without certified payroll represent $2,877,461 of
expenditures out of a total population tested for wage rate requirements of $32,780,066.

Cause:

The Division does not have adequate internal controls and policies and procedures in place
to ensure that certified payrolls are being submitted and reviewed timely.

Effect:

The Division is not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award. Laborers may not be paid wages at the DOL prevailing wage
rate.

Recommendation:

We recommend that the Division implement policies and procedures to ensure that certified
payrolls are being submitted and reviewed timely by program personnel.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

44

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–009 INTERNAL CONTROLS OVER SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
(Prior Year Finding 2017–004)
Federal Program Information:

Federal Agency and Program Name
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

CFDA #

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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:

New River Community and Technical College’s internal controls are not adequate to ensure
that the Schedule of Expenditures of Federal Awards (SEFA) accurately reports all federal
student financial assistance. The institution did not have adequate segregation of duties over
the process; the preparer of the SEFA was also the reviewer.

Questioned Costs:

N/A

Context:

Total Student Financial Assistance (SFA) cluster expenditures for the State of West Virginia
were $627,234,851 for the year ended June 30, 2018. Total SFA cluster expenditures for New
River Community and Technical College were $4,609,194 for the year ended June 30, 2018.

Cause:

New River Community and Technical College does not have adequate internal controls to
ensure the SEFA is accurate.

Effect:

New River Community and Technical College is not properly reviewing their SEFA and
errors and/or misstatements could go undetected. This could result in not charging SFA
awards correctly.

Recommendation:

We recommend that New River Community and Technical College ensure staff responsible
for the preparation of the SEFA have the resources needed to accurately prepare the SEFA
and that there are segregation of duties in the preparation and review of the SEFA.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

45

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–010 INTERNAL CONTROLS OVER CASH MANAGEMENT
Federal Program Information:

Federal Agency and Program Name
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

CFDA #

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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:

For the seven cash drawdowns selected from West Liberty University and the five cash
drawdowns selected from West Virginia Northern Community and Technical College in our
internal control testing, no evidence of review and approval of the drawdown was maintained.

Questioned Costs:

N/A

Context:

Total Student Financial Assistance (SFA) cluster expenditures were $627,234,851 for the
year ended June 30, 2018. SFA cluster expenditures for West Liberty University and West
Virginia Northern Community and Technical College were $20,556,015 and $5,226,315, for
the year ended June 30, 2018.

Cause:

Internal controls and policies and procedures relating to cash management are not robust
enough to ensure a second level review and approval are performed.

Effect:

The institution could drawdown incorrect or excess cash amounts resulting in noncompliance
with federal regulations.

Recommendation:

We recommend that the institution strengthen their procedures to ensure drawdown requests
are properly reviewed and approved.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

46

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–011 SPECIAL TESTS AND PROVISIONS – DISBURSEMENTS TO OR ON BEHALF OF
STUDENTS
Federal Program Information:

Criteria:

Federal Agency and Program Name
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

CFDA #

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

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 nonFederal 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 the two disbursement notifications selected for testing at West Virginia State University,
the institution did not provide the following in writing: the anticipated date and the amount
of disbursement. For one of the disbursement notifications selected for testing at Shepherd
University and one selected for West Virginia University at Parkersburg, the institution could
not provide documentation of the letter sent to the student. The total sample selected for
testing was 60.

Questioned Costs:

N/A

Context:

Total Direct Loan, Federal Perkins Loan, and TEACH Grant expenditures for the SFA cluster
were $497,111,725 for the year ended June 30, 2018. The total Direct Loan, Federal Perkins
Loan, and TEACH Grant expenditures for West Virginia State University, Shepherd
University, and West Virginia University at Parkersburg were $12,223,418, $18,317,661, and
$5,465,483, respectively for the year ended June 30, 2018.

47

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–011 SPECIAL TESTS AND PROVISIONS – DISBURSEMENTS TO OR ON BEHALF OF
STUDENTS
Cause:

Internal controls and policies and procedures related to the institutions’ disbursement
notifications did not encompass all of the required elements.

Effect:

Institutions were not in compliance with the requirements related to disbursement
notification. Policies and procedures related to the institutions’ disbursement notifications did
not encompass all of the required elements.

Recommendation:

We recommend that the institutions implement internal controls and policies and procedures
to ensure that all required information is part of the disbursement notifications sent to students
and that supporting documentation for disbursement notifications is maintained and archived
to allow for evidence of the institution’s compliance with federal guidelines.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

48

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–012 SPECIAL TESTS AND PROVISIONS – ENROLLMENT REPORTING
(Prior Year Findings 2017–006, 2016–008, 2015–015, 2014–011, 2013–028, 2012–43, 2012–47,
2012–49, 2011–22)
Federal Program Information:

Criteria:

Federal Agency and Program Name
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

CFDA #

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

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 nonFederal 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:

For one student selected from West Liberty University, one student selected from Fairmont
State University, and one student selected from Pierpont Community and Technical College
in our compliance sample of 60 students who withdrew, graduated, or enrolled but never
attended, the respective institutions did not promptly notify the appropriate entities of a
change in the student’s status in a timely and accurate manner.
For the students noted above, there were timing and status discrepancies between the
information reported by the institution to the Clearinghouse and their subsequent reporting
of enrollment detail to National Student Loan Data System (NSLDS).
Further the following institutions did not have internal controls in place surrounding the
enrollment reporting process for the selections made: West Virginia State University and
West Virginia University at Parkersburg.

Questioned Costs:

N/A

49

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–012 SPECIAL TESTS AND PROVISIONS – ENROLLMENT REPORTING
(Prior Year Findings 2017–006, 2016–008, 2015–015, 2014–011, 2013–028, 2012–43, 2012–47,
2012–49, 2011–22) (continued)
Context:

Total Direct Loan and Pell expenditures for the SFA cluster in total were $564,756,672 for
the year ended June 30, 2018. The total Direct Loan and Pell expenditures for West Liberty
University, Fairmont State University, Pierpont Community and Technical College, West
Virginia State University and West Virginia University at Parkersburg were $17,804,943,
$24,674,202, $8,567,902, $17,195,181, and $10,802,530, respectively for the year ended
June 30, 2018.

Cause:

Furthermore, the following institutions did not have internal controls in place surrounding
the enrollment reporting process for the selections made: West Virginia State University and
West Virginia University at Parkersburg.

Effect:

The institutions are not promptly notifying the NSLDS of changes in student status in an
accurate manner; thus, inaccurate information is reported to the NSLDS.

Recommendation:

This is a repeat finding. 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 and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

50

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–013 SPECIAL TESTS AND PROVISIONS – INTERNAL CONTROLS OVER BORROWER DATA
TRANSMISSION AND RECONCILIATION
(Prior Year Findings 2017–007, 2016–006)
Federal Program Information:

Federal Agency and Program Name
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

CFDA #

84.007/84.033/
84.038/84.063/
84.268/84.379/
93.264/93.342/
93.364/93.925

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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:

For the two months selected for testing of Direct Loan School Account Statement (SAS)
reconciliation requirements at both West Liberty University and West Virginia University at
Parkersburg, proper reconciliations were completed by the institutions; however, there were
no policies or procedures in place to review the SAS reconciliations.

Questioned Costs:

N/A

Context:

Total Direct Loan expenditures for the SFA cluster in total were $450,828,066 for the year
ended June 30, 2018. The total Direct Loan expenditures for West Liberty University and
West Virginia University at Parkersburg were $13,903,587 and $5,465,483, respectively for
the year ended June 30, 2018.

Cause:

Written procedures detailing the process to reconcile loans from Common Origination and
Disbursement (COD) records to Banner exist, as provided in narrative form during the audit.
However, management represented that a formal reconciliation review process has not been
successfully implemented.

Effect:

The absence of proper reconciliations could result in the institution’s financial records for
Direct Loan expenditures to be improperly stated.

Recommendation:

We recommend that management implement a reconciliation process that monthly
reconciliations are performed and saved as documented in the institution’s written procedure,
including documentation of supervisor review and approval. In addition, management needs
to ensure that all data received from COD is maintained within their records to facilitate audit
procedures.

51

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–013 SPECIAL TESTS AND PROVISIONS – INTERNAL CONTROLS OVER BORROWER DATA
TRANSMISSION AND RECONCILIATION
(Prior Year Findings 2017–007, 2016–006) (continued)
Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

52

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–014 ELIGIBILITY
(Prior Year Findings 2017–008, 2016–012)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Education
Rehabilitation Services—Vocational Rehabilitation
Grants to State
Grant Award H126A180073

CFDA #
84.126

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 nonFederal 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).
29 USC §722(a)(6), states that the West Virginia Division of Rehabilitation Services
(WVDRS) must determine whether an individual is eligible for Vocational Rehabilitation
(VR) services within a reasonable period of time, not to exceed 60 days, after the individual
has submitted an application for the services unless (a) exceptional and unforeseen
circumstances beyond the control of the State VR agency preclude making an eligibility
determination within 60 days and the State agency and the individual agree to a specific
extension of time; or (b) the State VR Agency is exploring an individual’s abilities,
capabilities, and capacity to perform in work situations through trial work experiences.

Condition:

During testing of the Case Service Report (RSA-911), a performance report that provides
various data elements to the U.S. Department of Education, it was noted that 138 individuals
out of the 12,256 individuals reported did not have an eligibility determination performed
within the required 60 days from the date of application. A sample of 10 individuals were
selected from the 138, of those individuals 7 did not have an authorized extension on file.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Vocational Rehabilitation Grant were $30,307,347 for the
year ended June 30, 2018.

Cause:

WVDRS appears to have policies and procedures in place to address eligibility; however, it
has failed to actively enforce those procedures.

Effect:

Federal expenditures could be made for individuals who were potentially ineligible.

Recommendation:

We recommend that WVDRS strengthen the existing internal controls and policies and
procedures surrounding the approval of eligible participants and ensure the appropriate
completion of all eligibility determinations on a timely basis.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

53

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–015 REPORTING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Education
Rehabilitation Services—Vocational Rehabilitation
Grants to State
Grant Award H126A180073

CFDA #
84.126

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 nonFederal 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 200.302(b)(2) required that financial management system of each non-federal entity
must provide “Accurate, current, and complete disclosure of the financial results of each
Federal award or program in accordance with the reporting requirements set forth in
§§200.327 Financial reporting and 200.328 Monitoring and reporting program performance.
If a Federal awarding agency requires reporting on an accrual basis from a recipient that
maintains its records on other than an accrual basis, the recipient must not be required to
establish an accrual accounting system. This recipient may develop accrual data for its reports
on the basis of an analysis of the documentation on hand. Similarly, a pass-through entity
must not require a subrecipient to establish an accrual accounting system and must allow the
subrecipient to develop accrual data for its reports on the basis of an analysis of the
documentation on hand.”

Condition:

The West Virginia Division of Rehabilitation Services (WVDRS) is responsible for preparing
the SF-425, Federal Financial Report, semiannually. The SF-425 is used to track the status of
financial data tied to a particular Federal Grant Award. The SF-425 report should be
complete, accurate, and prepared in accordance with the required accounting basis. There was
an error in reporting the amount of cash receipts on the March 31, 2018, report. The amount
of a cash draw down on April 6, 2018 of $3,038,948, was erroneously included as part of
cash receipts for the quarter ended March 31, 2018.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Vocational Rehabilitation Grant were $30,307,347 for the
year ended June 30, 2018.

Cause:

WVDRS appears to have policies and procedures in place to review the SF-425 prior to
submission; however, it has failed to actively enforce those procedures.

Effect:

The cumulative amount of actual cash received from the Federal agency as of the reporting
period end date was overstated $3,038,948.

Recommendation:

We recommend that WVDRS enforce the existing policies and procedures surrounding the
review and approval of the SF-425 report prior to submission.

54

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–015 REPORTING
(continued)
Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

55

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–016 SPECIAL TESTS AND PROVISIONS – COMPLETION OF INDIVIDUAL PLAN FOR
EMPLOYMENT (IPES)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Education
Rehabilitation Services—Vocational Rehabilitation
Grants to State
Grant Award H126A180073

CFDA #
84.126

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 nonFederal 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).
29 USC §722(b)(3)(F), states that if an individual is determined eligible for Vocational
Rehabilitation (VR) services, the West Virginia Division of Rehabilitation Services
(WVDRS) and the eligible individual must develop an Individualized Plan for Employment
(IPE) as soon as possible, but not later than a deadline of 90 days after the date of the
determination of eligibility, unless WVDRS and the eligible individual agree to an extension
of that deadline to a specific date by which the individualized plan for employment shall be
completed.

Condition:

Two of the 40 eligible individual IPEs tested were not completed within 90 days or within
the period of extension.

Questioned Costs:

Unknown

Context:

Total federal expenditures for the Vocational Rehabilitation Grant were $30,307,347 for the
year ended June 30, 2018.

Cause:

WVDRS appears to have policies and procedures in place to address completion of IPEs;
however, it has failed to actively monitor the compliance of those policies and procedures.

Effect:

Federal expenditures could be made for individuals who do not meet the requirements of the
program.

Recommendation:

We recommend that WVDRS monitor and enforce the existing policies and procedures
surrounding the timely completion of IPEs for eligible participants.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

56

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–017 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS
(Prior Year Findings 2017–002, 2016–017, 2015–025, 2014–016, 2013–034, 2012–51, 2011–46,
2010–43, 2009–43, 2008–55)
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Temporary Assistance for Needy Families (TANF)
Cluster
Grant Awards 2016G996115, 2017G996115, and
2018G996115
Low-Income Home Energy Assistance
Grant Awards G-16B1WVLIEA, G-17B1WVLIEA,
G-1701WVLIE4, and G-18B1WVLIEA
Child Care and Development Fund (CCDF) Cluster
Grant Awards G1701WVCCDF and
G1801WVCCDF
Foster Care—Title IV-E
Grant Awards 1701WVFOST and 1801WVFOST
Adoption Assistance
Grant Awards 1701WVADPT and 1801WVADPT
Children’s Health Insurance Program (CHIP)
Grant Awards 1705WV5021 and 1805WV5021
Medicaid Cluster

CFDA #
93.558
93.568
93.575/93.596
93.658
93.659
93.767
93.775/93.777/
93.778

Grant Awards 1705WV5MAP, 1705WV5ADM,
1705WVIMPL, 1705WVINCT, 1805WV5MAP,
1805WV5ADM, 1805WVIMPL, and
1805WVINCT
Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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.

57

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–017 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS
(Prior Year Findings 2017–002, 2016–017, 2015–025, 2014–016, 2013–034, 2012–51, 2011–46,
2010–43, 2009–43, 2008–55) (continued)
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 programs and federal compliance requirements impacted.
Federal Program

System

Compliance Requirements Impacted

Children’s Health
Insurance Program
(CHIP)

RAPIDS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility;
Level of Effort

Temporary Assistance for
Needy Families (TANF)
Cluster

RAPIDS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility

Low-Income Home
Energy Assistance

RAPIDS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility

Medicaid Cluster

RAPIDS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility

Adoption Assistance

FACTS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility

Foster Care – Title IV-E

FACTS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility,
Special Tests and Provisions – Operation of a Foster Care Demonstration
Project, Special Tests and Provisions – Payment Rate Setting and Application

Child Care and
Development Fund
(CCDF) Cluster

FACTS

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility

Cause:

Policies and procedures have not been adequately updated for changes in the processing of
eligibility. 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.

58

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–017 DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS
(Prior Year Findings 2017–002, 2016–017, 2015–025, 2014–016, 2013–034, 2012–51, 2011–46,
2010–43, 2009–43, 2008–55) (continued)
Recommendation:

This is a repeat finding, and 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 and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

59

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–018 REPORTING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Temporary Assistance for Needy Families (TANF)
Cluster
Grant Award 2018 – 2017G996115
Grant Award 2017 – 2016G996115

CFDA #
93.558

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 nonFederal 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).
45 CFR section 265.9(c)(5) requires “each State must provide the average monthly total
number or the total number of eligible families served for which the state claims Maintenance
of Effort (MOE) expenditures at the end of the fiscal year.”

Condition:

In the ACF 204 report submitted to the federal government for the federal fiscal year ended
September 30, 2018, the key line item “Total Number of Families Served under the Program
with MOE Funds” was overstated by 6,079 cases by using actual caseload, rather than using
average caseload throughout the year.

Questioned Costs:

Unknown

Context:

Total federal expenditures for TANF for the fiscal year ended June 30, 2018, were
$101,766,325. The total amount of State MOE for the federal fiscal year ended September 30,
2018, was $34,446,446.

Cause:

Formula errors in supporting documentation resulted in an incorrect submission to the federal
government which was not identified during the review process.

Effect:

The TANF program is not in compliance with federal requirements regarding the accuracy
of number of families served under the program that are to be reported on the ACF 204 report.

Recommendation:

Management should refine their precision of review to include a review of the formulas in
the supporting spreadsheets related to specific program requirements.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

60

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–019 SPECIAL TESTS AND PROVISIONS – INTERNAL CONTROLS OVER CHILD SUPPORT
NON-COOPERATION, PENALTY FOR REFUSAL TO WORK, AND ADULT CUSTODIAL
PARENT OF CHILD UNDER SIX WHEN CHILD CARE NOT AVAILABLE
(Prior Year Findings 2017–010, 2016–016, 2015–024, 2014–018, 2013–036, 2012–56, 2011–44,
2010–41)
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Temporary Assistance for Needy Families (TANF)
Cluster
Grant Award 2018–2017G996115
Grant Award 2017–2016G996115

CFDA #
93.558

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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 and Human Resources (DHHR) has policies and
procedures in place surrounding the issuance or removal of sanctions, however, DHHR could
not provide adequate documentation that the control was operating effectively.

Questioned Costs:

N/A

Context:

Total federal expenditures for TANF for the fiscal year ended June 30, 2018, were
$101,766,325.

Cause:

There is lack of sufficient documentary evidence to support that the controls are operating as
designed related to 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
internal control over the issuance or removal of sanctions.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

61

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–020 SPECIAL TESTS AND PROVISIONS – CHILD SUPPORT NON-COOPERATION
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Temporary Assistance for Needy Families (TANF)
Cluster
Grant Award 2018–2017G996115

CFDA #
93.558

Criteria:

2 CFR Section 200.608 (d) states the auditee must “provide the auditor with access to
personnel, accounts, books, records, supporting documentation and other information as
needed for the auditor to perform the audit required by this part.”

Condition:

For 1 of the 40 cases tested for child support non-cooperation, the benefit recipient had no
sanction for child support during the year and should not have been included in the population
for this compliance requirement. This conflicting data caused the auditor to be unable to
determine if population was complete and accurate to test the compliance requirement.

Questioned Costs:

Unknown

Context:

Total federal expenditures for TANF for the fiscal year ended June 30, 2018, were
$101,766,325.

Cause:

There are insufficient internal controls in place surrounding the generation and review of
populations provided to the auditor.

Effect:

The auditor was unable to determine if the auditee was in compliance with the specified
compliance requirement.

Recommendation:

We recommend that management implement policies and procedures to ensure that complete
and accurate population data can be generated from RAPIDS for the compliance area.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

62

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–021 ALLOWABILITY AND ELIGIBILITY
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Low-Income Home Energy Assistance
Grant Award G–16B1WVLIEA
Grant Award G–17B1WVLIEA
Grant Award G–1701WVLIEA
Grant Award G–18B1WVLIEA

CFDA #
93.568

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 nonFederal 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 eligibility compliance requirements of LIHEAP require the West Virginia Department
of Health and Human Resources (DHHR) to determine whether federal monies are spent in
accordance with the eligibility guidelines promulgated by 42 USC 8624(b)(2).

Condition:

During our testing of 60 benefit payments for eligibility and allowability, we noted the
following:
For two of the 60 cases reviewed, there was not adequate documentation surrounding the
caseworker’s verification of the recipient’s income.
For one of the 60 cases, there was conflicting information between the case records and
electronic records regarding heat source and calculation.
For four of the 60 cases, there was not adequate documentation surrounding the
caseworker’s verification of the recipient’s utility bill or wood/coal receipt.

Questioned Costs:

$1,930 – CFDA #93.568; $1,641 related to Grant Award G–18B1WVLIEA and $289 related
to Grant Award G–17B1WVLIEA

Context:

The seven instances represent $1,930 of benefit payments out of total benefit payments
$16,715. Total payments for benefit assistance for the LIHEAP program for the fiscal year
ended June 30, 2018, were $18,330,558. The federal expenditures for the LIHEAP program
for the fiscal year ended June 30, 2018, were $27,565,054.

Cause:

The program has internal controls and policies and procedures in place, however, the control
is not robust enough to identify benefit payment issues including that supporting
documentation is maintained.

Effect:

Payments have been made for ineligible recipients and some payments were not properly
approved and/or supported with appropriate documentation.

63

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–021 ALLOWABILITY AND ELIGIBILITY
(continued)
Recommendation:

We recommend that DHHR evaluate the effectiveness of the current training programs for
the LIHEAP program to ensure adequate technical training is provided. Furthermore, DHHR
should follow established policies and procedures to ensure that necessary review and
approvals are obtained and the appropriate documentation is maintained in the recipient case
files.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

64

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–022 SPECIAL TESTS AND PROVISIONS – FRAUD DETECTION AND REPAYMENT CONTROLS
(Prior Years Findings 2017–014, 2016–021)
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Child Care and Development Fund (CCDF) Cluster
Grant Award G1601WVCCDF
Grant Award G1701WVCCDF

CFDA #
93.575/93.596

Criteria:

2 CFR 200.303 states that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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:

Child Care payments resulting from fraud are identified and documented within quarterly
reconciliation spreadsheets. The current year quarterly reconciliation spreadsheets identified
two fraudulent claims established in the previous fiscal year but were not reported until fiscal
year 2018.

Questioned Costs:

N/A

Context:

Total federal expenditures for the CCDF Cluster for fiscal year ended June 30, 2018, were
$40,908,137.

Cause:

DHHR experienced significant staff turnover during the fiscal year which caused a lack of
timeliness in the way fraudulent claims were identified and reported.

Effect:

Payments resulting from fraud may not be identified and recovered in a reasonable amount
of time.

Recommendation:

DHHR should ensure its internal controls and policies and procedures are robust enough to
ensure fraudulent claims are identified and tracked through the reconciliation process
beginning in the year of identification. In addition, should adequately train new staff on the
processes and controls surrounding the fraud detection and recovery reconciliation process to
ensure that all fraudulent claims are identified in the appropriate fiscal year.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

65

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–023 ELIGIBILITY DOCUMENTATION
(Prior Year Findings 2017–015, 2016–022, 2015–029, 2014–024, 2013–040, 2012–59)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Adoption Assistance
Grant Awards 1701WVADPT and 1801WVADPT

CFDA #
93.659

2 CFR 200.303 requires that the DHHR 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).
Section 473 of the Social Security Act requires that the Adoption Assistance Agreement must
be in effect prior to the adoptive parents’ receipt of the Adoption Subsidy. Also, 45 CFR
1356.40 requires the Adoption Assistance Agreement must be signed and in effect at the time
of or prior to the final decree of adoption, and a copy of the signed agreement must be given
to each party. Further, the eligibility compliance requirements of the Adoption Assistance
program require the West Virginia Department of Health and Human Resources (DHHR) to
determine whether federal monies are spent in accordance with the eligibility guidelines
promulgated by the Adoption Assistance and Child Welfare Act of 1980. West Virginia State
Code §49-3-1 states that consent by an agency or department to adopt a child must be given
and a statement of relinquishment and termination of parental rights must be obtained from
the birth parents. The Adoption Assistance Policy Manual states that an Adoption Placement
Agreement (SSADP48) must be completed and signatures obtained as part of the preliminary
adoption procedures after the parental rights have been terminated if the child is not registered
on the Adoption Resource Network (ARN).

Condition:

Five of the 60 cases reviewed for eligibility did not have documents on file to determine
eligibility:
One case had an Adoption Placement Agreement signed after the Adoption
Assistance Agreement. The total payment amount associated with this case was
$600, charged to Grant Award 1801WVADPT.
Two cases were missing the Adoption Placement Agreement, Adoption Assistance
Agreement, Release and Consent form, and the IV-E eligibility determination form.
The total payment amount associated with these cases was $631 ($315.52 each),
charged to Grant Award 1801WVADPT.
One case did not specify a subsidy amount in the Adoption Assistance Agreement,
and the Adoption Placement Agreement was not signed or dated by the Social
Worker. The total payment amount associated with this case was $600, charged to
Grant Award 1701WVADPT.
One case was missing the Adoption Placement Agreement and the Adoption
Assistance Agreement. The total payment amount associated with this case was
$600, charged to Grant Award 1701WVADPT.

66

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–023 ELIGIBILITY DOCUMENTATION
(Prior Year Findings 2017–015, 2016–022, 2015–029, 2014–024, 2013–040, 2012–59) (continued)
Questioned Costs:

$2,431 – CFDA #93.659; $1,231 related to Grant Award 1801WVADPT and $1,200 related
to Grant Award 1701WVADPT

Context:

The five instances represent $2,431 of adoption payments out of a total population of benefit
payments tested for eligibility of $34,705. Total federal expenditures for the Adoption
Assistance program were $39,237,964 for the year ended June 30, 2018.

Cause:

Management indicated that the lack of inclusion of the proper forms in the case files and
inconsistency in the timing of sign-offs were oversights by the caseworker.

Effect:

Documentation supporting the original eligibility determination could not be located.
Potentially ineligible claims were paid using federal funds.

Recommendation:

We recommend that DHHR review the current staffing and training programs of the Adoption
Assistance Office to ensure sufficient staff levels are maintained and adequate technical
training is provided. Furthermore, the DHHR should establish policies and procedures to
ensure that necessary documentation is filed in the adoption case files.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

67

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–024 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Health and Human Services
Medicaid Cluster

CFDA #
93.775/93.777/
93.778

Grant Awards
1705WV5MAP;1705WV5ADM;1705WVIMPL;
1705WVINCT;1805WV5MAP;1805WV5ADM;
1805WVINCT;1805WVIMPL
Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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 435.10 requires a “State plan must (a) Provide that the requirements of this part are
met; and (b) Specify the groups to whom Medicaid is provided, as specified in subparts B, C,
D of this part, and the conditions of eligibility for individuals in those groups. Per the
Medicaid State Plan, “the Bureau for Medical Services, the single State agency, is the Office
of State Government responsible for the administration of the plan under Title XIX of the
Social Security Act. The Bureau for Medical Services has the authority to make rules and
regulations that it follows in administering the plan or that are binding upon local agencies
that administer the plan.” Per the Bureau of Medical Services manual, chapter 800 section 2,
the Rate Setting Division sets payment rates for services provided by hospitals, physicians,
and other health care providers participating in the West Virginia Medicaid program. Rates
are set annually for more than 35,000 covered services. Additionally, the Unit is responsible
for setting rates for the Bureau’s supplemental payments.”

Condition:

One of the 60 transactions tested was not calculated and paid using the correct resource-based
related value scale (RBRVS) fee schedule.

Questioned Costs:

$0.26 – CFDA #93.778 related to Grant Award 1805WV5MAP

Context:

The exception represented $0.26 of the total $16,381 sampled. Total federal expenditures for
the Medicaid program were $3,056,393,061 for the year ended June 30, 2018.

Cause:

One of the indices included in the rate calculation of Resource Based Relative Value Scale
(RBRVS Fee schedule) was omitted. It was not updated to reflect the “West Virginia specific”
index. The omitted index applied to claims with a date of service January 1, 2018, through
April 30, 2018. The error resulted in an overpayment to providers. Because the WV DHHR
discovered its own error, the RBRVS fee schedule was changed on May 1, 2018, to correct
the error in the calculation. If a claim with a date of service from January 1, 2018, to April
30, 2018, was submitted for payment after May 1, 2018, the new fee schedule was applied.

Effect:

Medicaid providers were overpaid for Medicaid services.

68

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–024 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES
(continued)
Recommendation:

We recommend that management implement internal controls and policies and procedures to
require a review the RBRVS fee schedule for any updates before they are input into
production calculations for errors prior to adopting the rate schedules.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

69

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–025 INTERNAL CONTROLS OVER REPORTING
(Prior Year Findings 2017–020, 2016–025)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Disaster Grants – Public Assistance (Presidentially
Declared Disasters)
Grant Award FEMA–4061-DR–WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.036

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 nonFederal 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).
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”

Condition:

Management of the West Virginia Division of Homeland Security and Emergency
Management (DHSEM) prepared and submitted revisions to SF-425, Federal Financial
Reports, without going through an appropriate review and approval process. Additionally,
the required quarterly performance reports, the FEMA Form 009-0-111, are not reviewed and
approved.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Disaster Grants – Public Assistance (Presidentially
Declared Disasters) program were $32,459,031 for the year ended June 30, 2018.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the reporting process to require an appropriate review and approval.

Effect:

Federal reports may be submitted with errors or lack of supporting documentation and not be
identified on a timely basis.

70

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–025 INTERNAL CONTROLS OVER REPORTING
(Prior Year Findings 2017–020, 2016–025) (continued)
Recommendation:

We recommend that DHSEM internal controls and policies and procedures over the report
preparation and submission process. We recommend that the review be performed by an
individual independent of the data entry process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

71

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–026 INTERNAL CONTROL OVER ALLOWABILITY
Federal Program Information:

Federal Agency and Program Name
U.S. Department of Homeland Security
Disaster Grants – Public Assistance (Presidentially
Declared Disasters)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.036

Criteria:

2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal 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).OMB Circular A-133 section 300b states that the non-federal entity is
responsible for maintaining “internal control over Federal programs that provides reasonable
assurance that management is managing Federal awards in compliance with laws,
regulations, and the provisions of contracts or grant agreements that could have a material
effect on each of its Federal programs.”

Condition:

One of the forty payroll transactions and one of the forty nonpayroll transactions selected for
testing from the West Virginia Division of Highways (the Division) expenditures were not
properly reviewed and approved.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Disaster Grants – Public Assistance (Presidentially
Declared Disasters) program were $32,459,031, for the year ended June 30, 2018.

Cause:

The Division does not have adequate policies and procedures in place to ensure all
transactions are reviewed and approved.

Effect:

The Division may not identify noncompliance with federal statutes, regulations, and the terms
of the conditions of the federal award including allowability. Expenditures may be paid that
are not allowable.

Recommendation:

We recommend that the Division implement internal controls and policies and procedures to
ensure that expenditures are properly reviewed and approved before being charged to a
federal award.

72

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–026 INTERNAL CONTROL OVER ALLOWABILITY
(continued)
Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

73

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–027 CASH MANAGEMENT
(Prior Year Finding 2017–017)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Disaster Grants – Public Assistance (Presidentially
Declared Disasters)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.036

2 CFR 200.305(b)(8) requires that a non-Federal entity must “maintain advance payments of
Federal awards in interest-bearing accounts, unless the following apply.
i.

The non-Federal entity receives less than $120,000 in Federal awards per year.

ii. The best reasonably available interest-bearing account would not be expected to earn
interest in excess of $500 per year on Federal cash balances.
iii. The depository would require an average or minimum balance so high that it would not
be feasible within the expected Federal and non-Federal cash resources.
iv. A foreign government or banking system prohibits or precludes interest bearing
accounts.”
2 CFR 200.305(b)(9) states that “interest earned on Federal advance funds deposited in
interest-bearing accounts must be remitted annually to the Department of Health and Human
Services, Payment Management System.”
Condition:

The West Virginia School Building Authority (SBA) was not holding their advance payments
of federal awards in interest-bearing accounts during fiscal year 2018. Beginning in February
2018, the SBA began transferring the advance payments to interest-bearing accounts. By
June 30, 2018, the SBA had transferred all funds to interest bearing accounts. In addition,
interest earned in excess of $500 for fiscal 2018 was not remitted back to the Department of
Health and Human Services, Payment Management System.

Questioned Costs:

Unknown

74

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–027 CASH MANAGEMENT
(Prior Year Finding 2017–017) (continued)
Context:

Total advance payments of federal awards held in non-interest-bearing accounts until
February 2018 for the Disaster Grants – Public Assistance (Presidentially Declared Disasters)
program were $6,238,757, which originated in the prior fiscal years. Beginning in February
2018, the SBA began transferring the advance payments to interest-bearing accounts. By June
30, 2018, the SBA had transferred all funds to interest bearing accounts. As of June 30, 2018,
interest earned on the interest-bearing accounts was $17,657. However, interest earned in
excess of $500 was not remitted back to the Department of Health and Human Services,
Payment Management System.

Cause:

The SBA was not aware of the requirement to hold advance payments in interest-bearing
accounts until the middle of fiscal year 2018. Furthermore, the SBA failed to remit interest
earned on the unexpended amounts to the WV Department of Homeland Security (DHSEM);
therefore, DHSEM did not remit the interest earned to the US Department of Homeland
Security Emergency Management on an annual basis.

Effect:

The DHSEM is not in compliance with the federal rules and regulations regarding cash
management.

Recommendation:

We recommend that the DHSEM develop internal controls and policies and procedures to
ensure that all advance payments of federal awards be held in interest-bearing accounts and
to ensure that interest earned on cash advances is tracked and remitted to the Federal
government on an annual basis.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

75

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–028 SUBRECIPIENT CASH MANAGEMENT
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Disaster Grants – Public Assistance (Presidentially
Declared Disasters)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.036

2 CFR 200.303 requires that Institutions 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).
OMB Circular A-133 section 300b requires that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
2 CFR 200.305(b) requires that “payments methods must minimize the time elapsing between
the transfer of funds from the United States Treasury or the pass-through entity and the
disbursement by the non-Federal entity.”
Additionally, 2 CFR 200.305(b)(3) states that “when the reimbursement method is used, the
Federal awarding agency or pass-through entity must make payment within 30 calendar days
after receipt of the billing, unless the Federal awarding agency or pass-through entity
reasonably believes the request to be improper.”
OMB Circular A-110 requires that procedures be implemented to ensure that subrecipients
minimize the time elapsing between the transfer of Federal funds from the recipient and the
disbursement of funds for program purposes.

Condition:

For eight of the forty subrecipient payments selected for testing, the West Virginia Division
of Homeland Security and Emergency Management (DHSEM) failed to reimburse the
subrecipients within 30 calendar days after receipt of the billing.

76

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–028 SUBRECIPIENT CASH MANAGEMENT
(continued)
Questioned Costs:

N/A

Context:

Total federal and subrecipient expenditures for the Disaster Grants – Public Assistance
(Presidentially Declared Disasters) program were $32,459,031 and 15,164,213, respectively,
for the year ended June 30, 2018. The eight instances represent $938,299 of expenditures out
of a total population tested for subrecipient cash management of $5,614,185.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
subrecipient payment requests to ensure federal funds are being reimbursed timely for
expenditures incurred.

Effect:

DHSEM is not in compliance with the cash management requirements of this program.
DHSEM is not reimbursing subrecipients on a timely basis.

Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures over
the subrecipient payment process to ensure that reimbursements are made within 30 calendar
days after receipt of the billing.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

77

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–029 SUBRECIPIENT MONITORING
(Prior Years Findings 2017–018, 2016–024)
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Disaster Grants – Public Assistance (Presidentially
Declared Disasters)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.036

2 CFR 200.331 establishes pass-through entity responsibilities which include (1) monitoring
“the activities of subrecipients as necessary to ensure that Federal awards are used for
authorized purposes in compliance with laws, regulations, and the provisions of contracts or
grant agreements and that performance goals are achieved,” and (2) ensuring that
subrecipients expending $750,000 or more in Federal awards during the subrecipient's fiscal
year have met the audit requirements for that fiscal year.
OMB Circular No. A-133, Subpart D §400 requires a pass-through entity to “monitor the
activities of subrecipients as necessary to ensure that federal awards are used for authorized
purposes in compliance with laws, regulations, and the provisions of contracts or grant
agreements and that performance goals are achieved.” Pass-through entities are required to
develop monitoring procedures including programmatic and financial monitoring to ensure
subrecipients have used federal funds for authorized purposes.

Condition:

DHSEM did not monitor the activities of the subrecipients as necessary, nor was a review
completed on Uniform Guidance audit reports posted to the State Auditor’s website until June
2018.

Questioned Costs:

Unknown

Context:

Total federal expenditures for the thirty-nine subrecipients and total federal expenditures for
the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were
$15,164,213 and $32,459,031, respectively, for the year ended June 30, 2018.

Cause:

Management did not have effective internal control and policies and procedures in place
during the fiscal year. Management did not have adequate staff with appropriate training to
complete the monitoring process during the fiscal year.

Effect:

Subrecipients may not be in compliance with the terms of the subrecipient grant agreement,
have unallowable expenditures and or audit findings that are not identified timely and
corrected.

78

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–029 SUBRECIPIENT MONITORING
(Prior Years Findings 2017–018, 2016–024) (continued)
Recommendation:

DHSEM should continue to follow their formalized policies implemented at year-end for
developing and tracking subrecipient monitoring reports, for receiving and tracking
subrecipient audit reports, and for following up on any instances of subrecipient compliance
or internal control findings to ensure they are resolved in a timely manner.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

79

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–030 SUBRECIPIENT CASH MANAGEMENT
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Hazard Mitigation Grant (HMGP)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.039

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
2 CFR 200.305(b) requires that “payments methods must minimize the time elapsing between
the transfer of funds from the United States Treasury or the pass-through entity and the
disbursement by the non-Federal entity.”
Additionally, 2 CFR 200.305(b)(3) states that “when the reimbursement method is used, the
Federal awarding agency or pass-through entity must make payment within 30 calendar days
after receipt of the billing, unless the Federal awarding agency or pass-through entity
reasonably believes the request to be improper.”
OMB Circular A-110 requires that procedures be implemented to ensure that subrecipients
minimize the time elapsing between the transfer of Federal funds from the recipient and the
disbursement of funds for program purposes.

Condition:

For eight of the sixteen subrecipient payments selected for testing, the West Virginia Division
of Homeland Security and Emergency Management (DHSEM) failed to reimburse the
subrecipients within 30 calendar days after receipt of the billing.

80

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–030 SUBRECIPIENT CASH MANAGEMENT
(continued)
Questioned Costs:

N/A

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Hazard
Mitigation Grant program were $4,735,620 and $5,328,656, respectively, for the year ended
June 30, 2018. The eight instances represent $787,913 of expenditures out of a total
population tested for subrecipient cash management of $1,282,255.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
subrecipient payment requests to ensure federal funds are being reimbursed timely for
expenditures incurred.

Effect:

DHSEM is not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award. By not reimbursing subrecipients for expenditures incurred
timely, the completion of projects may be delayed and vendors may not be paid timely.

Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures over
the subrecipient payment process to ensure that reimbursements are made within 30 calendar
days after receipt of the billing.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

81

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–031 SUBRECIPIENT ELIGIBILITY
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Hazard Mitigation Grant (HMGP)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.039

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 nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in the Federal Government”
issued by the Comptroller General of the United States and the “Internal Control Integrated
Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”
2 CFR 200.508(d) says an auditee must “provide the auditor with access to personnel,
accounts, books, records, supporting documentation, and other information as needed for the
auditor to perform the audit required by this part.”

Condition:

DHSEM did not provide timely supporting documentation to the auditors. Missing supporting
documentation includes:
Eligibility for Subrecipients
For 6 of the 8 subrecipients selected for testing, DHSEM did not provide the FEMA
Approved Mitigation Plan to allow the auditors to determine if eligibility
requirements were met. Total federal expenditures for these subrecipients were
$1,578,214.
For 8 of the 8 subrecipients selected for testing, DHSEM did not provide the signed
grant agreement with the subrecipient.
Subrecipient Monitoring
For 8 of the 8 subawards selected for testing, DHSEM did not provide documentation
to show that the subrecipient was made aware of the award information required by
2 CFR section 200.331(a).

82

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–031 AUDIT DOCUMENTATION
(continued)
Questioned Costs:

$1,578,214 – CFDA #97.039; $3,261 related to Grant Award FEMA–4132-DR–WV,
$1,203,187 related to Grant Award FEMA–4210-DR–WV, $281,024 related to Grant Award
FEMA–4220-DR–WV, $50,451 related to Grant Award FEMA–4221-DR–WV, and $40,291
related to Grant Award FEMA–4273-DR–WV

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Hazard
Mitigation Grant program were $4,735,620 and $5,328,656, respectively, for the year ended
June 30, 2018.

Cause:

DHSEM was not able to provide timely supporting documentation to the auditors.

Effect:

Critical data supporting all compliance requirements is not adequately maintained by
DHSEM for use by the auditors.

Recommendation:

We recommend that DHSEM ensure that all documentation supporting transactions or
compliance requirements subject to audit be maintained and readily available if requested.
Timely receipt of supporting documentation is crucial for the completion of the audit.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

83

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–032 MATCHING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Hazard Mitigation Grant (HMGP)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.039

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
44 CFR 206.432(c) states that “all mitigation measures approved under the State’s grant will
be subject to the cost sharing provisions established in the FEMA-State Agreement. FEMA
may contribute up to 75 percent of the cost of measures approved for funding under the
Hazard Mitigation Grant Program for major disasters declared on or after June 10, 1993” and
“FEMA will not contribute to costs above the Federally approved estimate.”

Condition:

For 4 of the 23 transactions selected for matching, the West Virginia Division of Homeland
Security and Emergency Management (DHSEM) failed to properly match 25 percent of the
expenditure incurred.

Questioned Costs:

$104,117 – CFDA #97.039; $1,214 related to Grant Award FEMA-4273-DR-WV and
$102,903 related to Grant Award FEMA-4331-DR-WV

Context:

Total federal expenditures for the Hazard Mitigation Grant program were $5,328,656 for the
year ended June 30, 2018. The four instances represent $104,117 of expenditures out of a
total population tested for matching of $2,183,922.

84

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–032 MATCHING
(continued)
Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the matching to ensure that the matching requirement is being met.

Effect:

DHSEM is not be compliance with federal statutes, regulations, and the terms of the
conditions of the federal award.

Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures over
the matching process to ensure that the proper state match is being applied to all expenditures
incurred.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

85

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–033 REPORTING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Hazard Mitigation Grant (HMGP)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.039

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
Per 29 CFR section 97.20, “Grantees and subgrantees must maintain records which
adequately identify the source and application of funds provided for financially-assisted
activities. These records must contain information pertaining to grant or subgrant awards and
authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures,
and income.”

Condition:

For three of the nine SF-425, Federal Financial Reports, and both of the Quarterly
Performance Reports selected for testing, management of the West Virginia Division of
Homeland Security and Emergency Management (DHSEM) prepared and submitted the
reports, without going through an appropriate review and approval process. In addition, there
was no documentation to support the amounts reported in one SF-425 report, for the reporting
period July 1, 2017 to September 30, 2017, selected for testing.

Questioned Costs:

$143,369 – CFDA #97.039 related to Grant Award FEMA-4273-WV

Context:

Total federal expenditures for the Hazard Mitigation Grant program were $5,328,656 for the
year ended June 30, 2018.

86

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–033 REPORTING
(continued)
Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the reporting process.

Effect:

DHSEM is not in compliance with the federal rules and regulations regarding reporting.
Reporting errors could occur and not be identified on a timely basis.

Recommendation:

We recommend that DHSEM review its internal controls and policies and procedures over
the report review and approval process. At a minimum, such controls should include a
documented review and approval process that ensures reported amounts agree with
supporting documentation. We recommend that the review be performed by an individual
independent of the data entry process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

87

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–034 SUBRECIPIENT MONITORING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Hazard Mitigation Grant (HMGP)
Grant Award FEMA–4061-DR-WV
Grant Award FEMA–4071-DR–WV
Grant Award FEMA–4236-DR–WV
Grant Award FEMA–4210-DR–WV
Grant Award FEMA–4093-DR–WV
Grant Award FEMA–4221-DR–WV
Grant Award FEMA–4220-DR–WV
Grant Award FEMA–4219-DR–WV
Grant Award FEMA–4132-DR–WV
Grant Award FEMA–4059-DR–WV
Grant Award FEMA–4273-DR–WV
Grant Award FEMA–4331-DR–WV

CFDA #
97.039

2 CFR 200.303 requires that the West Virginia Division of Homeland Security and
Emergency Management 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).
OMB Circular A-133 section 300b requires that the West Virginia Division of Homeland
Security and Emergency Management is responsible for maintaining “internal control over
Federal programs that provides reasonable assurance that management is managing Federal
awards in compliance with laws, regulations, and the provisions of contracts or grant
agreements that could have a material effect on each of its Federal programs.”
2 CFR 200.331 establishes pass-through entity responsibilities which include evaluating (b)
each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms
and conditions of the subaward for purposes of determining the appropriate subrecipient
monitoring, (d) monitoring “the activities of subrecipients as necessary to ensure that Federal
awards are used for authorized purposes in compliance with laws, regulations, and the
provisions of contracts or grant agreements and that performance goals are achieved,” and (f)
Verify that every subrecipient is audited as required by Subpart F—Audit Requirements of
this part when it is expected that the subrecipient's Federal awards expended during the
respective fiscal year equaled or exceeded the threshold set forth in §200.501 Audit
requirements.
OMB Circular No. A-133, Subpart D §400 requires a pass-through entity to “monitor the
activities of subrecipients as necessary to ensure that federal awards are used for authorized
purposes in compliance with laws, regulations, and the provisions of contracts or grant
agreements and that performance goals are achieved.” Pass-through entities are required to
develop monitoring procedures including programmatic and financial monitoring to ensure
subrecipients have used federal funds for authorized purposes.

88

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–034 SUBRECIPIENT MONITORING
(continued)
Condition:

We noted the following issues related to subrecipient monitoring for the West Virginia
Division of Homeland Security and Emergency Management (DHSEM) for the Hazard
Mitigation Grant Program:
DHSEM is not completing subrecipient risk assessments.
Management indicated that they review completed auditor’s reports posted to the
State Auditor’s website; however, there is no evidence of this review or
documentation regarding resolution of any issues identified.

Questioned Costs:

Unknown

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Hazard
Mitigation Grant program were $4,735,620 and $5,328,656, respectively, for the year ended
June 30, 2018.

Cause:

Management of DHSEM implemented monitoring policies and procedures in June 2018, but
did not have adequate staff with appropriate training to complete the monitoring process
during the fiscal year.

Effect:

Subrecipients may not be in compliance with the terms of the subrecipient grant agreement,
have unallowable expenditures and or audit findings that are not identified timely and
corrected.

Recommendation:

DHSEM should implement their formalized policies developed at year-end for developing
and tracking subrecipient monitoring reports, for receiving and tracking subrecipient audit
reports, and for following up on any instances of subrecipient compliance or internal control
findings to ensure they are resolved in a timely manner.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

89

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–035 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

2 CFR 200.508(b) states, “The auditee must prepare appropriate financial statements,
including the schedule of expenditures of Federal awards.” The Federal Office of
Management and Budget issues instructions on how to prepare this schedule.
2 CFR 200.303(a) requires that a non-Federal entity must “establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award.”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”

Condition:

The West Virginia Division of Homeland Security and Emergency Management’s (DHSEM)
internal controls are not adequate to ensure the that the Schedule of Expenditures of Federal
Awards (SEFA) accurately reports all federal assistance. Our review of the SEFA for fiscal
year 2018 identified that various transactions occurring in 2017 were improperly excluded
from the 2017 SEFA and included on the 2018 SEFA. The total amount of 2017 expenditures
reported on the 2018 SEFA was $103,342.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018.

Cause:

DHSEM has not implemented adequate internal controls to ensure the SEFA is accurate.

Effect:

DHSEM is improperly reporting their federal expenditures and federal awards may not be
accurately charged.

Recommendation:

We recommend that DHSEM ensure staff responsible for the preparation of the SEFA have
the resources needed to accurately prepare the SEFA.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

90

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–036 ALLOWABILITY
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
2 CFR 200.508(d) says an auditee must “provide the auditor with access to personnel,
accounts, books, records, supporting documentation, and other information as needed for the
auditor to perform the audit required by this part.”

Condition:

Six of the 40 payroll transactions selected for testing were not properly reviewed and
approved. Additionally, for 38 of the 40 payroll transactions selected for testing, the amount
charged to the program was not able to be reconciled back to the employee’s pay stub for the
period selected for testing. Further, support was not provided for $848,870 in expenditures
listed on the SEFA.

Questioned Costs:

$922,168 – CFDA #97.042

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018. The 38 instances represent $73,298 of payroll
expenditures out of a total population tested of $77,421. Total payroll for the year for the
program was $209,222. Additionally, support was not provided for $848,870 in expenditures
listed of the SEFA.

Cause:

The West Virginia Division of Homeland Security and Emergency Management (DHSEM)
does not have adequate internal controls and policies and procedures in place to ensure all
transactions are reviewed and approved and that supporting documentation is retained.

91

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–036 ALLOWABILITY
(continued)
Effect:

DHSEM is not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award. Expenditures were paid that were not supported by the
DHSEM.

Recommendation:

We recommend that DHSEM implement controls to ensure that expenditures are properly
reviewed and approved before being charged to a federal award and that supporting
documentation is retained.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

92

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–037 SUBRECIPIENT CASH MANAGEMENT
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grant
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
2 CFR 200.305(b) requires that “payments methods must minimize the time elapsing between
the transfer of funds from the United States Treasury or the pass-through entity and the
disbursement by the non-Federal entity.”
Additionally, 2 CFR 200.305(b)(3) states that “when the reimbursement method is used, the
Federal awarding agency or pass-through entity must make payment within 30 calendar days
after receipt of the billing, unless the Federal awarding agency or pass-through entity
reasonably believes the request to be improper.”
OMB Circular A-110 requires that procedures be implemented to ensure that subrecipients
minimize the time elapsing between the transfer of Federal funds from the recipient and the
disbursement of funds for program purposes.

Condition:

For nine of the ten subrecipient payments selected for testing, the West Virginia Division of
Homeland Security and Emergency Management (DHSEM) failed to reimburse the
subrecipients within 30 calendar days after receipt of the billing.

Questioned Costs:

N/A

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Emergency
Management Performance Grant program were $3,245,967 and $5,072,094, respectively, for
the year ended June 30, 2018. The nine instances represent $406,953 of expenditures out of
a total population tested for subrecipient cash management of $433,622.

93

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–037 SUBRECIPIENT CASH MANAGEMENT
(continued)
Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
subrecipient payment requests to ensure federal funds are being reimbursed timely for
expenditures incurred.

Effect:

DHSEM is not in compliance with federal statutes, regulations, and the terms of the
conditions of the federal award. By not reimbursing subrecipients for expenditures incurred
timely, the completion of projects may be delayed and vendors may not be paid timely.

Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures over
the subrecipient payment process to ensure that reimbursements are made within 30 calendar
days after receipt of the billing.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

94

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–038 ELIGIBILITY FOR SUBRECIPIENTS
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
2 CFR 200.333 requires “Financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to a Federal award must be retained for a period of
three years from the date of submission of the final expenditure report or, for Federal awards
that are renewed quarterly or annually, from the date of the submission of the quarterly or
annual financial report, respectively, as reported to the Federal awarding agency or passthrough entity in the case of a subrecipient.”

Condition:

The West Virginia Division of Homeland Security and Emergency Management (DHSEM)
did not obtain and/or maintain documentation of subrecipient Emergency Operations Plans
Grants (EMPG) as required to determine that the subrecipient is eligible for any of the 19
subrecipients selected for testing.

Questioned Costs:

$901,411 – CFDA #97.042; $273,157 related to Grant Award EMW-2014-EP-00044 and
$628,254 related to Grant Award EMW-2015-EP-00050

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Emergency
Management Performance Grant program were $3,245,967 and $5,072,094, respectively, for
the year ended June 30, 2018. Total expenditures for subrecipients tested were $901,411.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the subrecipient eligibility process.

Effect:

DHSEM may not be in compliance with the federal statutes and regulations regarding
subrecipient eligibility. Funding may be awarded to subrecipients who have not complied
with EMPG funding guidelines.

95

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–038 ELIGIBILITY FOR SUBRECIPIENTS
(continued)
Recommendation:

We recommend that DHSEM review its internal controls and policies and procedures
regarding the subrecipient eligibility process. At a minimum, DHSEM should implement a
tracking system with a documented review and approval process that ensures an eligibility
determination for each potential subrecipient. We recommend that the review be performed
by an individual independent of the data entry process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

96

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–039 EARMARKING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
The U.S. Department of Homeland Security’s Notice of Funding Opportunity for the
Emergency Management Performance Grant (EMPG) allows that a State Emergency
Management Agency “may use up to five percent (5%) of the EMPG award for M&A
purposes.” Management and Administration (M&A) activities are those directly related to
managing and administering the EMPG award.

Condition:

The West Virginia Division of Homeland Security and Emergency Management (DHSEM)
charged M&A expenditures to EMPG grants, but DHSEM management did not track these
expenditures to ensure compliance with applicable earmarking requirements noted in the
award.

Questioned Costs:

Unknown

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the earmarking process.

Effect:

DHSEM may not be in compliance with the federal statutes and regulations regarding
earmarking. M&A expenditures could exceed maximum allowable thresholds.

97

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–039 EARMARKING
(continued)
Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures
regarding earmarking and M&A tracking process. At a minimum, DHSEM should implement
a tracking system with a documented review and approval process that ensures M&A
expenditure amounts do not exceed maximum allowable thresholds. We recommend that the
review be performed by an individual independent of the data entry process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

98

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–040 MATCHING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
The U.S. Department of Homeland Security’s Notice of Funding Opportunity for the
Emergency Management Performance Grant (EMPG) states that “the Federal share that is
used towards the EMPG budget shall not exceed 50 percent of the total budget. The state
must equally match (cash or in-kind) the Federal contribution pursuant to Sections 611(j) and
613 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Pub. L. No. 93288), as amended, (42 U.S.C. §§ 5121et seq.). Unless otherwise authorized by law, Federal
funds cannot be matched with other Federal funds.”

Condition:

For 1 of the 36 transactions selected for testing, the West Virginia Division of Homeland
Security and Emergency Management (DHSEM) failed to properly match 50 percent of the
expenditure incurred as required per the grant agreement.

Questioned Costs:

$40,203 – CFDA #97.042 related to Grant Award EMP-2016-EP-00002

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018. The one instance represents $40,203 of
expenditures out of a total population tested for matching of $561,238.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the matching to ensure that the matching requirement is being met.

Effect:

DHSEM is not be compliance with federal statutes, regulations, and the terms of the
conditions of the federal award.

99

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–040 MATCHING
(continued)
Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures over
the matching process to ensure that the proper state match is being applied to all expenditures
incurred.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

100

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–041 REPORTING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grant
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
Per 29 CFR section 97.20, “Grantees and subgrantees must maintain records which
adequately identify the source and application of funds provided for financially-assisted
activities. These records must contain information pertaining to grant or subgrant awards and
authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures,
and income.”

Condition:

Management of the West Virginia Division of Homeland Security and Emergency
Management (DHSEM) prepared and submitted various reports required under the
Emergency Management Performance Grant program without going through an appropriate
review and approval process. Reports submitted without approval included the following:
SF-425, Federal Financial Reports
SF-PPR, Performance Progress Reports
BSIR, Biannual Strategy Implementation Reports
THIRA, Threat and Hazard Identification and Risk Assessment
SPR, State Preparedness Report

101

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–041 REPORTING
(continued)
In addition, there was no documentation to support the expenditure amounts reported in one
SF-425 (2014 EMPG grant from July 1, 2017 through September 30, 2017 and 2016 EMPG
grant from January 1, 2018 through March 31, 2018 reports), Federal Financial Reports, and
the expended and obligated balance in all BSIR, Biannual Strategy Implementation Reports,
performance reports selected for testing which consisted of the following:
EMPG 2014 January 1, 2018 through June 30, 2018
EMPG 2015 January 1, 2018 through June 30, 2018
EMPG 2016 July 1, 2017 through December 31, 2017, and January 1, 2018 through
June 30, 2018
EMPG 2017 July 1, 2017 through December 31, 2017
Questioned Costs:

$1,914 – CFDA #97.042 Grant Award EMW-2014-EP-00044

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the reporting process.

Effect:

DHSEM is not in compliance with the federal rules and regulations regarding reporting.
Reporting errors could occur and not be identified on a timely basis.

Recommendation:

We recommend that DHSEM review its internal controls and policies and procedures over
the report review and approval process. At a minimum, such controls should include a
documented review and approval process that ensures reported amounts agree with
supporting documentation. We recommend that the review be performed by an individual
independent of the data entry process.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

102

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–042 SUBRECIPIENT MONITORING
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grant
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

2 CFR 200.303 requires that the West Virginia Department of Homeland Security 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).”
OMB Circular A-133 section 300b requires that the West Virginia Homeland Security is
responsible for maintaining “internal control over Federal programs that provides reasonable
assurance that management is managing Federal awards in compliance with laws,
regulations, and the provisions of contracts or grant agreements that could have a material
effect on each of its Federal programs.”
2 CFR 200.331 establishes pass-through entity responsibilities which include evaluating (b)
”each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms
and conditions of the subaward for purposes of determining the appropriate subrecipient
monitoring”, (d) monitoring “the activities of subrecipients as necessary to ensure that
Federal awards are used for authorized purposes in compliance with laws, regulatins, and the
provisions of contracts or grant agreements and that performance goals are achieved,” and (f)
verifying “that every subrecipient is audited as required by Subpart F—Audit Requirements
of this part when it is expected that the subrecipient's Federal awards expended during the
respective fiscal year equaled or exceeded the threshold set forth in §200.501 Audit
requirements.”
OMB Circular No. A-133, Subpart D §400 requires a pass-through entity to “monitor the
activities of subrecipients as necessary to ensure that federal awards are used for authorized
purposes in compliance with laws, regulations, and the provisions of contracts or grant
agreements and that performance goals are achieved.” Pass-through entities are required to
develop monitoring procedures including programmatic and financial monitoring to ensure
subrecipients have used federal funds for authorized purposes.

103

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–042 SUBRECIPIENT MONITORING
(continued)
Condition:

We noted the following issues related to subrecipient monitoring for the West Virginia
Division of Homeland Security and Emergency Management (DHSEM) for the Emergency
Management Performance Grant program:
DHSEM is not completing subrecipient risk assessments.
DHSEM is not documenting monitoring.
Management indicated that they review completed auditor reports posted to the State
Auditor’s website; however, there is no evidence of this review or documentation
regarding resolution of any issues identified.

Questioned Costs:

Unknown

Context:

Total federal expenditures for subrecipients and total federal expenditures for the Emergency
Management Performance Grant program were $3,245,967 and $5,072,094, respectively, for
the year ended June 30, 2018.

Cause:

Management of DHSEM did not have internal controls or policies and procedures in place
over subrecipient monitoring for the period of July 1, 2017 through May 31, 2018.

Effect:

Subrecipients may not be in compliance with the terms of the subrecipient grant agreement,
have unallowable expenditures and or audit findings that are not identified timely and
corrected.

Recommendation:

DHSEM should implement their formalized policies developed at year-end for developing
and tracking subrecipient monitoring reports, for receiving and tracking subrecipient audit
reports, and for following up on any instances of subrecipient compliance or internal control
findings to ensure they are resolved in a timely manner.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

104

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–043 SPECIAL TESTS AND PROVISIONS – CLOSEOUT REPORTING REQUIREMENTS
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
44 CFR 13.50(b) states that “within 90 days after the expiration or termination of the grant,
the grantee must submit all financial, performance, and other reports required as a condition
of the grant.”
2 CFR 200.343(a) states that “the non-Federal entity must submit, no later than 90 calendar
days after the end date of the period of performance, all financial, performance, and other
reports as required by the terms and conditions of the Federal award. The Federal awarding
agency or pass-through entity may approve extensions when requested by the non-Federal
entity.”
The U.S. Department of Homeland Security’s Notice of Funding Opportunity for the
Emergency Management Performance Grant (EMPG) requires that grantees must submit a
final closeout reporting package once a grant is closed.

Condition:

The West Virginia Division of Homeland Security and Emergency Management (DHSEM)
did not submit the required closeout reporting package within 90 days of the expiration of the
grant award.

Questioned Costs:

N/A

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the closeout reporting process.

105

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–043 SPECIAL TESTS AND PROVISIONS – CLOSEOUT REPORTING REQUIREMENTS
(continued)
Effect:

DHSEM is not in compliance with the federal statutes and regulations regarding the closeout
reporting requirements. The grant may not be properly closed out resulting in FEMA having
to administratively close the award; if this action is taken, consideration for subsequent
awards to DHSEM may be impacted or restricted.

Recommendation:

We recommend that DHSEM review its internal controls and policies and procedures in place
over the close out reporting process. At a minimum, controls should be in place to ensure that
all required reports are submitted within the 90 days of the expiration or termination of the
grant award.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

106

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–044 SPECIAL TESTS AND PROVISIONS – TRAINING AND EXERCISE PLAN REQUIREMENTS
Federal Program Information:

Criteria:

Federal Agency and Program Name
U.S. Department of Homeland Security
Emergency Management Performance Grants
Grant Award EMW-2014-EP-00044
Grant Award EMW-2015-EP-00050
Grant Award EMP-2016-EP-00002
Grant Award EMP-2017-EP-00005
Grant Award EMP-2018-EP-00003

CFDA #
97.042

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 nonFederal 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).”
OMB Circular A-133 section 300b states that the non-federal entity is responsible for
maintaining “internal control over Federal programs that provides reasonable assurance that
management is managing Federal awards in compliance with laws, regulations, and the
provisions of contracts or grant agreements that could have a material effect on each of its
Federal programs.”
The U.S. Department of Homeland Security’s Notice of Funding Opportunity for the
Emergency Management Performance Grant (EMPG) requires that recipients “develop a
multi-year Training and Exercise Plan (TEP) that identifies a combination of exercises and
associated training requirements identified in the Training and Exercise Plan Workshop
(TEWP). The recipient must “conduct no less than four quarterly exercises of any type and
one full-scale exercise within a 12-month period.” The recipient must submit an After Action
Report/Improvement Plan (AAR/IP) to report on the required exercises to the Regional
EMPG Program Manager no later than 90 days after completion of the exercise.
The U.S. Department of Homeland Security’s Notice of Funding Opportunity for the
Emergency Management Performance Grant (EMPG) also states that “all EMPG Program
funded personnel shall complete the following training requirements and record proof of
completion: NIMS Training, Independent Study (IS) 100, IS 200, IS 700, and IS 800. In
addition, personnel shall complete either the Independent Study courses identified in the
Professional Development Series or the National Emergency Management Basic Academy
delivered either by the Emergency Management Institute (EMI) or at a sponsored State, local,
tribal, territorial, regional or other, designated location.” Furthermore, “all EMPG-funded
personnel shall participate in no fewer than three exercises in a 12-month period.”

Condition:

Although the required exercises were completed and are tracked by the State Exercise
Coordinator, there is no documentation of the review of the AAR/IP reports submitted to the
Regional EMPG Program Manager. Additionally, there is no documentation indicating that
the AAR/IP reports were submitted within 90 days of the completion of the exercise.

107

 STATE OF WEST VIRGINIA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
for the Year Ended June 30, 2018

2018–044 SPECIAL TESTS AND PROVISIONS – TRAINING AND EXERCISE PLAN REQUIREMENTS
(continued)
For 21 of the 22 employees selected for testing, DHSEM was not able to provide
documentation that the employees met the required training requirements noted above.
Questioned Costs:

N/A

Context:

Total federal expenditures for the Emergency Management Performance Grant program were
$5,072,094 for the year ended June 30, 2018.

Cause:

DHSEM does not have adequate internal controls and policies and procedures in place over
the Training and Exercise Plan requirements.
The West Virginia Division of Homeland Security and Emergency Management (DHSEM)
does not have internal controls and policies and procedures in place to ensure that all EMPGfunded personnel complete the required training or participate in at least three exercises in
12-month period.

Effect:

DHSEM is not in compliance with the federal rules and regulations regarding the Training
and Exercise Plan requirements. The required AAR/IP reports documenting the exercises are
not reviewed and submitted within the required 90 day period. EMPG-funded personnel may
not be participating in the required number of exercises or receiving adequate training since
sufficient policies and procedures are not in place to track the training received by each
employee.

Recommendation:

We recommend that DHSEM implement internal controls and policies and procedures
regarding the Training and Exercise Plan requirements, including implementing policies and
procedures over the submission of the AAR/IP reports and over employee training and
exercise participation. At a minimum, DHSEM should document review and approval of the
AAR/IP reports to ensure they are in compliance with the requirements of the grant award
and submitted timely. DHSEM should also implement a tracking system with a documented
review and approval process that ensures all EMPG-funded personnel complete the required
training and participate in the required number of exercises.

Views of
Responsible
Officials and
Planned Corrective
Actions:

Management acknowledges the finding. See corrective action plan.

108

 CORRECTIVE
ACTION

PLAN

 

STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
CONTACT PERSON
For finding resolution and Single Audit matters, please contact Betsy
Chapman, West Virginia Department of Administration, Financial
Accounting and Reporting Section, 2101 Washington Street, E.,
Charleston, WV 25305 (Telephone 304-558-4083 ext. 301). E-mail:
Betsy.Chapman@wv.gov. The respective state agency identified in each
finding is responsible for the corrective action plan.
2018-001

FINANCIAL STATEMENT CLOSE PROCESS
Financial Accounting and Reporting Section
CFDA Number Not Applicable
The Financial Accounting and Reporting Section (FARS) will work
closely with the Department of Health and Human Resources to
understand the information provided and to better coordinate the timely
receipt of information to allow staff adequate time to review. FARS will
also evaluate the impact of new GASB pronouncements timelier.

2018-002

PERIOD OF PERFORMANCE
National Guard Military Operations and Maintenance (O&M)
CFDA Number 12.401
Regarding the three transactions that were incurred prior to the
beginning dates of the performance period, O&M has implemented
additional internal control procedures to prevent this from happening in
the future. In September 2018, before the transition from federal fiscal
year 2018 to 2019, O&M reminded all accounts payable personnel to be
cognizant of the service period dates on invoices. O&M instructed staff
to split the invoice payments so that the appropriate service periods
were charged to the proper federal year. This process will continue on
an annual basis. The agency level document approvers were also
reminded to look at service periods on payment documents to make sure
the correct federal fiscal year is being charged. O&M will also perform
internal audits of sample transactions occurring each month to monitor
the implementation of these procedures beginning in February 2019.

109

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
For the one transaction where the performance period payments were
not liquidated within the 90 day period, O&M has implemented the
internal control procedures mentioned above. In addition to these
procedures, O&M is developing procedures to track open contracts with
service periods after the 90 day period. O&M will prepare a list of grants
that have valid extension requests. Each month, O&M will review the
status of the outstanding payments to be made against the grants to
determine if the grants can be closed out or if an additional extension
request will need submitted for approval. These additional procedures
will be implemented beginning in February 2019.
2018-003

PROGRAM INCOME MONITORING
National Guard Military Operations and Maintenance (O&M)
CFDA Number 12.401
Regarding the United States Property and Fiscal Office (USPFO) report,
O&M agrees that program income was earned related to this program.
However, O&M disagrees with the amount of program income earned
by the Full Time Dining Operations Cooperative Agreement. O&M will
be meeting with various staff members and USPFO staff in the next
month to determine the allowable expenses in calculating Program
Income for this cooperative agreement. O&M is currently tracking
Program Income based on the audit criteria and calculations as defined
in the agreement. In December 2018, O&M began tracking program
income on reimbursement vouchers. O&M started deducting the
program income earned from the audit from the appropriate vouchers.
By March 31, 2019, O&M will have an agreement of the allowable
expenses and completed procedures for tracking and allocating total cost
of previous Program Income earned, as well as accounting for current
Program Income for this cooperative agreement.

110

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-004

INTERNAL CONTROLS OVER REPORTING
West Virginia Community Advancement and Development
Office (WVCAD)
CFDA Number 14.228
WVCAD is in the process of developing internal control policies and
procedures as they relate to the review and approval of the reporting
process.

2018-005

INTERNAL
CONTROLS
OVER
ALLOWABILITY
AND
PROCUREMENT
West Virginia Community Advancement and Development
Office (WVCAD)
CFDA Number 14.228
WVCAD agrees that Horne Invoice 3259, dated 8/11/2017, in the amount
of $96,250 was not paid in accordance with purchasing guidelines within
WV Code §5A-3-17. However, no one in the Administrative Services
Division (the finance group who pay the invoices and procurement group
that work with Central Purchasing) were aware of the existence of task
orders 3 through 8 until February 27, 2018 when they were first brought
to the Administrative Services Division’s attention. At that time, the
Administrative Services Division notified the Central Purchasing
Division in Department of Administration who notified the Governor’s
Office who then put a hold on the program. The Administrative Services
Division also met with WVCAD management and the Commerce
Secretary and Deputy Secretary to make them aware of the issues. The
invoice in question was paid against the original contract; therefore,
reducing the amount available of the original contract. It did not result
in additional dollars paid to the vendor above the original contract
amount.
In July 2018, a new department-wide standard operating procedure was
implemented for purchases over $25,000 requiring additional levels of
review and approval to ensure that all task orders and supporting
documentation are obtained and valid prior to payment. Directors and
procurement staff attended a mandatory meeting where procurement

111

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
issues were discussed, and the agencies had input into the development
of the SOP before its implementation.
Seven contracts were entered prior to receiving the Authority to Use
Grant Funds, but no work was assigned, or money expended to any
contractor prior to the funds being released. There has been significant
staff turnover with those who were involved in the procurement and
decision-making process at the time the contracts were signed, but it’s
WVCAD’s understanding this was an allowable action for pre-award
costs. WVCAD has reached out to HUD to for additional guidance on
this topic. Once HUD provides clarification, WVCAD will incorporate all
guidance into this finding, future action, and include any necessary
updates in the Policies and Procedures for the CDBG-DR program.
WVCAD plans to have these policies implemented before October 2019.
2018-006

FEDERAL HIGHWAYS ADMINISTRATION PAYBACK
Division of Highways (DOH)
CFDA Number 20.205, 20.219, 20.224, 23.003
A policy and procedure has been developed to address Performance End
Dates (PED). It is in its final stages of review and will be implemented
in March 2019. In addition, DOH has revised the BF98 (DOH
Authorization Request) form to include a field for the PED when a new
project is being established.

2018-007

SCHEDULE OF EXPENDITURES AND FEDERAL AWARDS
Division of Highways (DOH)
CFDA Number 20.205, 20.219, 20.224, 23.003
DOH understands the importance and necessity of having a timely
review and reconciliation of the records used in the preparation of the
financial statements. The Financial Reporting Section will work to
improve their reconciliation procedures between REMIS and wvOASIS.

112

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-008

WAGE RATE REQUIREMENTS
Division of Highways (DOH)
CFDA Number 20.205, 20.219, 20.224, 23.003
DOH will reissue previous guidance to all current project supervisors on
the overall importance of accurately documenting labor compliance.
DOH will also provide additional training for supervisors with a specific
focus on reviewing and documenting certified payrolls. DOH will
implement additional training for newly hired engineers and project
supervisors that will cover labor compliance enforcement and reviewing
certified payrolls beginning in April 2019.

2018-009

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
New River Community and Technical College (New River)
CFDA Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
93.264, 93.342, 93.364, 93.925
New River has made the internal control correction that the preparer
and the reviewer of the SEFA will not be the same person.

2018-010

CASH MANAGEMENT
West Liberty University and West Virginia Northern
Community and Technical College
CFDA Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
93.264, 93.342, 93.364, 93.925
West Liberty University (West Liberty) response
West Liberty’s CFO monitors cash on a daily basis and it is the view of
West Liberty that no incorrect or excess cash amounts are drawn down
that would result in noncompliance of federal law. To strengthen and
tighten the internal controls over the draw down process, West Liberty
implemented a formal review and approval over this process in July
2018.
West Virginia Northern Community and Technical College
(Northern) Response
Northern has strengthened internal controls regarding the draw
down/return of Student Financial Assistance (SFA) funds. In

113

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
October 2018, a second review of the supporting documentation was
added before initiation of any drawdown or return of funds can be
submitted.
2018-011

SPECIAL TESTS AND PROVISIONS – DISBURSEMENTS TO OR
ON BEHALF OF STUDENTS
West Virginia State University, Shepherd University, and West
Virginia University at Parkersburg
CFDA Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
93.264, 93.342, 93.364, 93.925
West Virginia State University (WVSU) response
WVSU management implemented a corrective action plan to address
this matter in December 2018. The Office of Student Financial Aid met
with the Information Technology Department and updated the
student/parent borrower Right to Cancel notification. The updates
include borrower specific loan information with the amount and date of
disbursement disclosed. All required information is now present on the
Right to Cancel notification. Policies and procedures were updated
based on the corrective action plan. In compliance with the updates, all
supporting documentation will be maintained and archived by the Office
of Student Financial Aid.
Shepherd University (Shepherd) response
Shepherd has implemented a corrective plan of action. Beginning in
October 2018, when sending the disbursement notifications, Shepherd
is including the financial aid manager to receive all emails in order to
maintain evidence of the delivery of the emails sent to students and
parents.
West Virginia University at Parkersburg (WVUP) response
WVUP had not verified the disbursement notifications from the thirdparty refund vendor in several semesters, and were unaware that the
notification process changed to something less detailed because of
efficiency considerations. WVUP is very aware of being accountable for
the vendor’s processes. Upon discovery of the changes to the vendor’s
process, WVUP will no longer be relying on the vendor to provide the

114

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
required disbursement information. Beginning with the Spring 2019
semester, WVUP is implementing a disbursement notification process
that will send the required information concerning aid disbursement
using the Banner system so that it can be documented and tracked by
student. The new notification process will ensure that all students are
properly notified. Any disbursement notifications provided by the
vendor will be in addition to WVUP’s institutional notification.
2018-012

SPECIAL TESTS AND PROVISIONS – ENROLLMENT
REPORTING
West Liberty University, Fairmont State University, Pierpont
Community and Technical College, West Virginia State
University, and West Virginia University at Parkersburg
CFDA Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
93.264, 93.342, 93.364, 93.925
West Liberty University (West Liberty) response
In FY 2019, West Liberty has updated the reporting to all graduated
students within 20 days through Student Clearinghouse to meet all
federal requirements. To increase accuracy in reporting, West Liberty
has also started manually checking graduated students in National
Student Loan Data System (NSLDS) on day 25 to ensure the federal
regulation on reporting for graduates is met.
Fairmont State University (Fairmont) response
Fairmont’s Registrar has implemented a corrective action plan to
address the enrollment reporting finding, effective November 1, 2018.
All future transmission dates will be reviewed to ensure the enrollment
reporting for subsequent term files occur every 30 days beginning with
the 1st day of the term. In addition, the schedule will be reviewed and
modified with the coordination of Fairmont’s NSLDS school
representative to ensure the 30-day reporting requirement is met.
Pierpont Community and Technical College (Pierpont) response
Pierpont’s Registrar staff updates Clearinghouse per the Clearinghouse
schedule, which then is updated in NSLDS. Pierpont’s financial aid
office will follow a procedure to spot check the NSLDS reporting once
every 30 days for accuracy which began in April 2017. Pierpont will work

115

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
with Clearinghouse to determine if NSLDS can be updated timely, or if
manual updates will need to be made moving forward.
West Virginia State University (WVSU) response
WVSU’s registrar established a process in December 2018 to check
submission files prior to sending them to the National Clearinghouse.
The Office of Registration will confirm the report is correct prior to
submission and document this step. If errors occur once submission files
are sent, the Office of the Registrar will continue to document for
resolution. A folder of all issues will be kept of all enrollment errors.
Confirmation of receipt will be documented.
West Virginia University at Parkersburg (WVUP) response
WVUP acknowledges the enrollment verification process lacked
sufficient documentation for the auditors to verify the review had been
conducted. In response to this finding, WVUP has modified the policy
and procedures to require the financial aid staff to review all enrollment
report files submitted to the National Clearinghouse by records staff for
accuracy and completeness no less than every 30 days. In addition,
WVUP will create a routine form so that staff involved in review and
verification process can sign off and date when the process has been
completed.
2018-013

SPECIAL TESTS AND PROVISIONS – BORROWER DATA
TRANSMISSION AND RECONCILIATION
West Liberty University and West Virginia University at
Parkersburg
CFDA Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
93.264, 93.342, 93.364, 93.925
West Liberty University (West Liberty) response
In October 2018, West Liberty was informed of the internal controls
required over the reconciliation process. At that time, one counselor was
responsible for pulling in files from COD and Banner to complete all
reconciliation requirements. All loans and grants were updated and
documented with the counselor. In October 2018, West Liberty
implemented policies and procedures whereby a counselor is still
completing the reconciliation process, but the Director of Financial Aid

116

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
is reviewing all reconciliations for completion as well as spot checking
updates and monthly balances.
West Virginia University at Parkersburg (WVUP) response
WVUP performs a proper reconciliation of the Direct Loan School
Account Statement to the amounts disbursed to students. However,
WVUP agrees that written policies and procedures need to be developed
to ensure compliance with this requirement. Therefore, WVUP
Financial Aid officials are in the process of writing and implementing
new policies and procedures for the Direct Loan implementation process,
including the usage of the SAS reports in a monthly reconciliation
process. These policies and procedures will be effective for the spring
2019 semester. WVUP will utilize the Direct Loan Reconciliation
participant guide provided by the Department of Education to ensure
that policies and procedures are compliant. The new policy will include
the utilization of a routine form so that staff involved in the review and
verification process can sign off and date when the process is complete.
2018-014

ELIGIBILITY
Division of Rehabilitation Services (DRS)
CFDA Number 84.126
DRS will continue to review and strengthen training and procedures
around eligibility timeframes and form completion, as well as continue
to remind clients they have a shared responsibility to follow through and
remain in contact with their counselor.

2018-015

REPORTING
Division of Rehabilitation Services (DRS)
CFDA Number 84.126
DRS agrees that the April 6, 2018 draw was included in the report. Total
cash draws matched the G5 system at the date of preparation rather
than the report ending date. DRS will ensure appropriate report review
procedures are enforced to specifically compare cash draw and reporting
cut-off dates before submission.

117

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-016

SPECIAL TESTS AND PROVISIONS – COMPLETION OF IPES
Division of Rehabilitation Services (DRS)
CFDA Number 84.126
After reviewing this finding, DRS has implemented additional steps to
enforce the agency’s policies and procedures. Specifically, a new feature
has been added to the electronic case management system to actively
alert counselors and their direct manager prior to the 90-day deadline
for IPE development. An automated email will be sent to the counselor
and their direct manager with a list of cases that have been in Status 10
for 75 or more days without an extension. This active alert will ensure
that IPEs are developed in a timelier manner and allow for DRS
managers to have increased awareness of case activity. This increased
awareness will enable managers to proactively provide supervision and
guidance to counselors to ensure that cases are moved from application
to eligibility to IPE development in a timely manner. Additionally, DRS
does not concur with the effect of the finding, “Federal Expenditures
could be made for individuals who do not meet the requirements of the
program.” DRS has internal controls and safeguards in place to ensure
compliance with federal regulations, including the prevention of federal
expenditures made for individuals who do not meet the requirements of
the program.

2018-017

DHHR INFORMATION SYSTEM AND RELATED BUSINESS
PROCESS CONTROLS
Department of Health and Human Resources (DHHR)
CFDA Number 93.558, 93.568, 93.575, 93.596, 93.658, 93.659,
93.767, 93.775, 93.777, 93.778
The DHHR continues to assess the possibility of implementing
additional controls related to automatic payments. For the foster care
benefit payments that are issued automatically without evidence of
someone formally reviewing the payments, this is a long-standing issue
that is driven by the business processing rules in place within the DHHR
programmatic bureau (Bureau for Children and Families – BCF). It is
not a system issue because the system is simply supporting the business
rules requested by the DHHR BCF. Nonetheless, many controls and
verifications exist around the establishment of eligibility for Federal

118

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
financial participation. Supervisor approval is necessary to place a child
in a paid foster care setting, which in turn will generate a monthly
payment, but the DHHR BCF is on record as defending their decision to
not require an additional approval process to release each month’s
payments, as the administrative burden and related cost of requiring a
secondary level of review for all case information entered into the system
would far outweigh the benefits derived from such a process.
For the foster care benefit payments that are requested and approved
by the same person, this too is a long-standing issue that is driven by
the business processing rules in place within the DHHR BCF. However,
the U.S. Department of Health and Human Services has issued a new
requirement that existing Statewide Automated Child Welfare
Information System (SACWIS) make modifications or build new
systems to conform to a new set of system requirements known as a
Comprehensive Child Welfare Information System (CCWIS). The
changes went into effect August 2016 and the state plans to begin
migration or implementation in October 2020. The CCWIS will replace
the SACWIS and the DHHR will be evaluating the new CCWIS and the
related control structure to improve the overall internal controls
surrounding foster care benefit payments.
For the adoption assistance benefit payments, an approval process does
not exist within the system, as this too was a business processing rule
established by the DHHR BCF at the time the system was developed
and implemented. However, the adoption subsidy function is limited to
only a few individuals in the entire state through database and security
roles. Since the subsidy is a negotiated benefit that must be declared
for the prospective parents, guardian ad-litem and judge to approve and
sign on the adoption finalization order, the amount and frequency has
already been decided upon and documented for all parties in the
adoption agreement. When defining the system requirements for the
new CCWIS, the DHHR will work with the DHHR BCF to establish an
approval process for adoption assistance benefit payments.

119

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-018

REPORTING
Department of Health and Human Resources (DHHR)
CFDA Number 93.558
To address the condition and correct the total number of families served
under the Work Supports program with maintenance of effort funds for
federal fiscal year 2018, the DHHR submitted a revised Annual Report
on TANF Programs under 45 CFR 265.9(c) and State Maintenance of
Effort Programs (Form ACF-204) to the HHS Administration for
Children and Families, Office of Family Assistance, on January 9, 2019.
The total number of families served under the Work Supports program
with maintenance of effort funds for federal fiscal year 2018 was revised
to 606, which represents the average monthly total for the fiscal year.
Preparing the ACF-204 report is a joint effort between the DHHR
Bureau for Children and Families, which is a programmatic bureau, and
the DHHR Office of Grants Management, which is an office under
DHHR Finance. To address the overall cause of the finding, but also
considering beyond the incorrect formula that led to the number of
families being overstated, the DHHR will expand its overall internal
controls surrounding the ACF-204 report by reexamining federal due
dates in relation to internal processes and procedures; requiring
additional levels of review within the Bureau for Children and Families
(programmatic staff and finance staff) and the Office of Grants
Management, as may be possible and practicable given internal
resources and constraints (e.g., staffing); and requiring stronger
assurances/confirmations (i.e., accountability) from the Bureau for
Children and Families and the Office of Grants Management prior to
certification of the report externally to the HHS Administration for
Children and Families.

120

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-019

SPECIAL TESTS AND PROVISIONS – CHILD SUPPORT NONCOOPERATION, PENALTY FOR REFUSAL TO WORK, AND
ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN
CHILD CARE NOT AVAILABLE
Department of Health and Human Resources (DHHR)
CFDA Number 93.558
The DHHR Bureau for Children and Families (BCF) maintains a log of
instances in which a supervisor approves his or her own sanction. The
BCF Policy Unit periodically reviews the log to ensure the sanctions are
reasonable; are applied in accordance with the policies and procedures
currently in place within the BCF surrounding the issuance and removal
of sanctions, as outlined within the West Virginia Income Maintenance
Manual; and are documented within the Recipient Automated Payment
Information Data System (RAPIDS). To improve upon the log, the BCF
Policy Unit will add documentation for each approval and denial, which
will include case records, emails, memos to the file, and other documents
scanned by the Family Support Specialist and/or Family Support
Supervisor.
The BCF Policy Unit will also review the current policy surrounding the
issuance and removal of sanctions and will update the policy for clarity
if deemed necessary, particularly in relation to the need to maintain
documentation that the policy is operating effectively (i.e., maintain
documentation surrounding all steps of the sanction process). The BCF
Policy unit will then work with the BCF Division of Training to review
the online Blackboard course surrounding the issuance and removal of
sanctions, will update the course if necessary, and will ensure that all
Family Support Specialists and Family Support Supervisors are current
with their training. Finally, as an additional level of control, the BCF
Policy Unit will create a Sanction Desk Guide for distribution to all WV
WORKS field staff, including but not limited to the Family Support
Specialists and Family Support Supervisors.

121

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-020

SPECIAL
TESTS
AND
PROVISIONS
–
SANCTIONS
COMPLIANCE
Department of Health and Human Resources (DHHR)
CFDA Number 93.558
The DHHR has already informed the relevant parties of this matter and
will ensure to the maximum extent possible that the auditors receive
complete and accurate populations surrounding child support noncooperation during fieldwork for fiscal year 2019. There are currently
general controls in place within the DHHR Bureau for Children and
Families (BCF) and the DHHR Office of Management Information
Services surrounding populations and other reports from the Recipient
Automated Payment Information Data System (RAPIDS). To address
the issue surrounding child support non-cooperation, the sanctions
related thereto, and the need to provide the auditors with complete and
accurate populations for all matters related to sanctions (not just child
support non-cooperation), the DHHR Office of Internal Control and
Policy Development will compile and organize the various policies and
procedures surrounding sanctions (i.e., will gain a greater
understanding of the controls already in place), will analyze those
controls against the Federal compliance requirements, and will schedule
a meeting with the relevant parties internal and external to the DHHR
prior to the start of fieldwork for the West Virginia Single Audit for the
year ended June 30, 2019. This will ensure that all relevant parties
understand the compliance requirement, the existing controls within
the DHHR, the audit approach and the required populations needed by
the auditors for sampling.
The relevant parties will include the DHHR BCF; the DHHR Office of
Management Information Services; the State’s independent auditors;
and the independent contractor that maintains RAPIDS and generates
the populations for the auditors.

122

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-021

ALLOWABILITY AND ELIGIBILITY
Department of Health and Human Resources (DHHR)
CFDA Number 93.568
The LIEAP Coordinator will create and send out a LIEAP Desk Guide
and LIEAP Application Checklist in February 2019 to all field staff that
process LIEAP Applications. The LIEAP Coordinator will review a
random sample of pending and non-PSC (Public Service Commision)
utility cases for accuracy.

2018-022

SPECIAL TESTS AND PROVISIONS – FRAUD DETECTION AND
REPAYMENT CONTROLS
Department of Health and Human Resources (DHHR)
CFDA Number 93.575 and 93.596
Corrective action was taken in September 2018. To address the finding,
the DHHR Bureau for Children and Families (BCF) developed a new
tracking tool, the purpose of which is to ensure, among other things, that
all fraudulent claims are identified in the appropriate fiscal year. More
specifically, the new tracking tool will ensure that all fraudulent
payments identified in a fiscal year are included within the population
provided to the State’s independent auditors, irrespective of whether
any repayments have been received and added to the expenses claimed
for the fiscal year. The DHHR BCF transmitted the new tracking tool
to the Resource and Referral Agencies on August 14, 2018, via email. To
account for the tracking tool within policy, the Division of Early Care
and Education also updated Section 2.3 (Operational and
Administrative Requirements) of the Policy and Procedure Manual for
Child Care Resource and Referral Services on September 21, 2018.

2018-023

ELIGIBILITY DOCUMENTATION
Department of Health and Human Resources (DHHR)
CFDA Number 93.659
The DHHR Bureau for Children and Families developed a revised
Adoption Subsidy and Services Standard Operating Procedure (SOP)
and distributed it on February 14, 2018, to field staff. The procedure
focuses on the steps field staff should be taking to ensure subsidy

123

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
payments and medical cards are entered promptly after an adoption
occurs. Furthermore, the procedure discusses the steps that need to be
taken to finalize an adoption record, what items are needed in the
record, and how to send this completed record to the state office. Finally,
the procedure discusses actions the state office will take should the
adoption record be missing information. The implementation of the
procedure was March 1, 2018.
The issues regarding signatures being obtained prior to parental
relinquishment is a training topic that will be discussed and
implemented in the Blackboard trainings. While the past errors that
may have occurred with documentation cannot be fixed, strides have
been made to ensure that future records are complete and accurate
before going to storage.
2018-024

ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE
COSTS/COST PRINCIPLES
Department of Health and Human Resources (DHHR)
CFDA Number 93.775, 93.777, and 93.778
Management will take steps to strengthen existing internal control
procedures over the review and approval of the Resource Based
Relative Value Scale (RBRVS) rates prior to implementation.
Management further believes that recent process changes will
provide additional time for rate setting and quality review that will
mitigate future opportunities for error. Beginning with the 2019
RBRVS fee schedule, the implementation date has been changed to
be effective April 1, 2019 and annually thereafter. This will permit
a more thorough quality review prior to implementation of the fee
schedule.

2018-025

INTERNAL CONTROLS OVER REPORTING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of DHSEM with

124

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
emphasis on Public Assistance Grants awards. Included in the revisions
is a policy for internal controls over the submission of federal financial
reports (SF 425), including appropriate review and approval processes.
DHSEM anticipates having all policies complete and updated by
February 15, 2019 with submission to FEMA Region III for review by
March 1, 2019.
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging team has and will continue to enable process changes.
2018-026

INTERNAL CONTROL OVER ALLOWABILITY
Division of Highways (DOH)
CFDA Number 97.036
DOH will re-emphasize the importance and necessity of the procedures
to review and approve expenditures throughout the workforce. These
procedures will be distributed to the workforce, and training will be
offered to ensure compliance.

2018-027

CASH MANAGEMENT
School Building Authority (SBA)
CFDA Number 97.036
The SBA has developed policies and procedures to ensure that all
advance payments of Federal awards be held in interest-bearing
accounts. In addition, there is a process in place to monitor accrued
interest and remit to the appropriate Department/Agency any amounts
over the cash advances in a timely manner.

125

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-028

SUBRECIPIENT CASH MANAGEMENT
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of DHSEM with
emphasis on Public Assistance Grants awards. Included in the revisions
is a policy related to the subrecipient payment process, including
appropriate review and approval. DHSEM will ensure a section is in the
policy specifying the flow of payment documents with emphasis on the
actual payment process to ensure that reimbursements are made within
30 calendar days after receipt of billing. DHSEM anticipates having
policies implemented by March 1, 2019.

2018-029

SUBRECIPIENT MONITORING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
At the end of FY 2018, DHSEM had a FEMA Region III approved
monitoring plan and was in the process of executing the plan. DHSEM
did not have an adequate staff with appropriate training until late 2018
and a formalized policy was not fully implemented until early 2019.
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging monitoring team has and will continue to enable process
changes and will help complete the required monitoring steps to ensure
compliance.

126

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-030

SUBRECIPIENT CASH MANAGEMENT
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.039
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of DHSEM with
emphasis on Hazard Mitigation Grant awards. Included in the revisions
is a policy related to the subrecipient payment process, including
appropriate review and approval. DHSEM will ensure a section is in the
policy specifying the flow of payment documents with emphasis on the
actual payment process to ensure that reimbursements are made within
30 calendar days after receipt of billing. DHSEM anticipates having
policies implemented by March 31, 2019.

2018-031

AUDIT DOCUMENTATION
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.039
Late in 2018, the CPA/Financial Officer for DHSEM resigned for a
position with another agency. Shortly after that resignation, DHSEM
hired a Chief Financial Officer (CFO). These two personnel changes
caused a significant gap in processes.
DHSEM is completing a rewrite of all Financial Policies, a section will
be included defining procedures related to documentation retainage.
DHSEM will also take steps to determine any necessary action needed
to prevent delays with providing supporting documentation from
reoccurring.
The placement of the new CFO and the creation of the Internal Review
Department will help to eliminate this problem in the future.

127

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-032

MATCHING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.039
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of WV DHSEM with
emphasis on Public Assistance and Mitigation Grant awards. Included
in the revisions is a policy related to the implementation of a MATCH
tracking system, to help ensure that proper state match is being applied
to all expenditures incurred. This policy will include steps for
appropriate review and approval. DHSEM anticipates having policies
implemented by March 31, 2019.

2018-033

REPORTING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.039
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of DHSEM with
emphasis on Public Assistance and Mitigation Grant awards. Included
in the revisions is a procedure related to the SF 425 report, including
appropriate review and approval process. DHSEM anticipates having
policies implemented by April 15, 2019.

2018-034

SUBRECIPIENT MONITORING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.039
At the end of FY 2018, DHSEM had a FEMA Region III approved
monitoring plan and was in the process of executing the plan. DHSEM
did not have an adequate staff with appropriate training until late 2018
and a formalized policy was not fully implemented until early 2019.
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and

128

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging monitoring team has and will continue to enable process
changes and will help complete the required monitoring steps to ensure
compliance.
2018-035

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
Late in 2018, the CPA/Financial Officer for DHSEM resigned for a
position with another agency. Shortly after that resignation, DHSEM
hired a Chief Financial Officer (CFO). These two personnel changes
caused a significant gap in processes, leading to the noted SEFA
problems.
DHSEM is completing a rewrite of all Financial Policies, including
SEFA preparation and balancing. This will be complete by the end of
February 2019. We also hired a CPA as lead in our Internal Review
Department who will review and test the policy.
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging monitoring team has and will continue to enable process
changes and will help complete the required monitoring steps to ensure
compliance.
Placement of the new CFO and hiring of the CPA will serve to eliminate
this problem in the future. DHSEM will balance the SEFA for the
remainder of FY 2019 and report status directly to the Internal Review
Department.

129

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-036

ALLOWABILITY
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
DHSEM is in the process of realigning and adding personnel to the
Emergency Management Performance Grants processing section. The
addition of these personnel serves to assist in mitigation of this finding.
Beginning the end of February 2019, a specific person will have the
responsibility to balance payroll to expenditures. DHSEM Quality
Control will by the end of February design a template (dashboard) to
clearly indicate progress in this process.
Further, the policies that will be implemented by the end of
February 2019, will provide detail sufficient to preclude this problem in
the future. These policies will address the review and approval process
for all transactions and the retainage of supporting documentation. The
Internal Control Section will have the responsibility to monitor the
internal controls relating to this finding.

2018-037

SUBRECIPIENT CASH MANAGEMENT
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
DHSEM staff is in the process of writing and/or updating all
processes/policies/procedures relating to all aspects of DHSEM with
emphasis on Public Assistance Grants and Emergency Management
Performance Grants (EMPG) awards. Included in the revisions is a
policy related to the subrecipient payment process, including
appropriate review and approval. DHSEM will ensure a section is in the
policy specifying the flow of payment documents with emphasis on the
actual payment process to ensure that reimbursements are made within
30 calendar days after receipt of billing. DHSEM anticipates having
policies implemented by the end of February 2019.

130

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging monitoring team has and will continue to enable process
changes and will help complete the required monitoring steps to ensure
compliance.
The DHSEM Internal Review Department will implement a process to
monitor subrecipient payments by the end of February 2019. An EMPG
employee will upkeep the data in the dashboard.
2018-038

ELIGIBILITY FOR SUBRECIPIENTS
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
Using the Notice of Funding Opportunity (NOFO) for all Emergency
Management Performance Grants (EMPG) open grants and all
upcoming EMPG grants, DHSEM will design a matrix detailing all
subrecipient eligibility requirements. All open grants and new grants
will be reviewed for allowability based on the grant criteria.
Further, the policies being updated will contain a subrecipient eligibility
section, specifically noting that the Internal Review Department will
review all grants to ensure proper procedures and approvals were done
in determining eligibility for each potential subrecipient. Detailed
monthly reports will be provided to the Director on a monthly basis
beginning the end of March 2019.

131

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-039

EARMARKING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
Effective March 1, 2019, DHSEM will design and implement a tracking
system detailing exact status of the Emergency Management
Performance Grants awards as compared to grant commitments. This
will be similar to a checkbook process. This system will help ensure
Management and Administrative (M&A) expenditures do not exceed
allowable thresholds.
This tracking will be monitored/validated by the Internal Review
Department – totally independent of the data entry. The tracker will be
reviewed first by internal control and then by the Director on a monthly
basis.
The DHSEM policies will detail and contain a section related to internal
controls regarding earmarking and M&A process. The policy will be
implemented by the end of February 2019.

2018-040

MATCHING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
Coupled with the tracker system detailing awards and expenditures, as
invoices/vouchers/receipts are applied, they will be reviewed to ensure
appropriate match requirements were met. The Internal Review
Department will review this process monthly and present to DHSEM.
As DHSEM updates policies, a section will be included related to the
matching process to ensure that the proper state match is being applied
to all expenditures incurred. Policies will be implemented by the end of
February 2019.

132

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-041

REPORTING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
During February and March 2019, DHSEM will review all reports and
implement a process to ensure appropriate review. The Internal Review
Department will be responsible for review and making corrections as
necessary and overseeing internal controls to ensure reported amounts
agree with supporting documentation. Monthly tracker reports will be
provided to the Director.
Policies and procedures will be written pertaining to the report review
and approval process. DHSEM anticipates having policies implemented
by the end of February 2019.

2018-042

SUBRECIPIENT MONITORING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
At the end of FY 2018, DHSEM had a FEMA Region III approved
monitoring plan and was in the process of executing the plan. DHSEM
did not have an adequate staff with appropriate training until late 2018
and a formalized policy was not fully implemented until early 2019.
In the last quarter of FY 2018, DHSEM started to assemble an Internal
Review Department. This department will review all policies and
procedures prior to implementation and test them during production.
The department consists of a CPA, a Quality Advisor, a lead monitor,
two monitors, and an internal review/monitoring business manager. As
DHSEM progressed through the end of 2018 and into 2019, this
emerging monitoring team has and will continue to enable process
changes and will help complete the required monitoring steps to ensure
compliance.

133

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

CORRECTIVE ACTION PLAN
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2018-043

CLOSEOUT REPORTING REQUIREMENTS
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
For each Emergency Management Performance Grants (EMPG) open
year and new awards, a tracker will detail the process for close out,
including the 90-day requirement. This review will be completed
monthly by the Internal Review Department who will then report to the
Director.
A policy will be written related to the closeout reporting process.
Internal controls will also be put in place to ensure all required reports
are submitted within 90 days of the expiration or termination of the
grant award. DHSEM anticipates having policies implemented by the
end of February 2019.

2018-044

TRAINING AND EXERCISE PLAN REQUIREMENTS
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.042
Using the Notice of Funding Opportunity (NOFO) for all open and
upcoming Emergency Management Performance Grants (EMPG)
grants, DHSEM will design a matrix/dashboard detailing all required
training and exercises. All open grants and new grants will be reviewed
for allowability based on the grant criteria to ensure all EMPG
personnel complete the required training.
Further, the policies being updated will contain a grants “requirements”
section which will include language regarding the training and exercise
plan requirements and submission of the AAR/IP reports. The Internal
Review Department will review all grants for compliance with
requirements of the grant award and ensure that all reports are
submitted timely. Detailed monthly reports will be provided to the
Director beginning the end of March 2019.

134

  UMMAR 
CHED ULE OF
PRIOR A UDI 

FINDINGS

 

STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-001

SPECIAL TESTS AND PROVISIONS – EBT CARD SECURITY
Department of Health and Human Resources (DHHR)
CFDA Numbers 10.551 and 10.561
Resolved
Corrective action taken for FY 2018.

2017-002
2016-017
2015-025
2014-016
2013-034
2012-51
2011-46
2010-43
2009-43
2008-55

DHHR INFORMATION SYSTEM AND RELATED BUSINESS
PROCESS CONTROLS
Department of Health and Human Resources (DHHR)
CFDA Numbers 10.551, 10.561, 93.558, 93.568, 93.575, 93.596,
93.658, 93.659, and 93.767
Partially Resolved

The DHHR continues to assess the possibility of implementing
additional controls related to automatic payments. For the foster care
benefit payments that are issued automatically without evidence of
someone formally reviewing the payments, this is a long-standing
issue that is driven by the business processing rules in place within the
DHHR programmatic bureau (Bureau for Children and Families –
BCF). It is not a system issue because the system is simply supporting
the business rules requested by the DHHR BCF. Nonetheless, many
controls and verifications exist around the establishment of eligibility
for Federal financial participation. Supervisor approval is necessary to
place a child in a paid foster care setting, which in turn will generate a
monthly payment, but the DHHR BCF is on record as defending their
decision to not require an additional approval process to release each
month’s payments, as the administrative burden and related cost of
requiring a secondary level of review for all case information entered
into the system would far outweigh the benefits derived from such a
process.

135

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
For the foster care benefit payments that are requested and approved
by the same person, this too is a long-standing issue that is driven by
the business processing rules in place within the DHHR BCF.
However, the U.S. Department of Health and Human Services has
issued a new requirement that existing Statewide Automated Child
Welfare Information System (SACWIS) make modifications or build
new systems to conform to a new set of system requirements known as
a Comprehensive Child Welfare Information System (CCWIS). The
changes went into effect August 2016 and the state plans to begin
migration or implementation in October 2020. The CCWIS will replace
the SACWIS and the DHHR will be evaluating the new CCWIS and
the related control structure to improve the overall internal controls
surrounding foster care benefit payments.
For the adoption assistance benefit payments, an approval process
does not exist within the system, as this too was a business processing
rule established by the DHHR BCF at the time the system was
developed and implemented. However, the adoption subsidy function
is limited to only a few individuals in the entire state through database
and security roles. Since the subsidy is a negotiated benefit that must
be declared for the prospective parents, guardian ad-litem and judge to
approve and sign on the adoption finalization order, the amount and
frequency has already been decided upon and documented for all
parties in the adoption agreement.
When defining the system
requirements for the new CCWIS, the DHHR will work with the
DHHR BCF to establish an approval process for adoption assistance
benefit payments. See current year finding 2018-017.
2017-003

PROCUREMENT PROCEDURES
Department of Health and Human Resources (DHHR)
CFDA Numbers 10.551, 10.561, 93.558, 93.568, 93.575, 93.596,
93.658, 93.659, 93.767, 93.775, 93.777, and 93.778
Resolved
Corrective action taken for FY 2018.

136

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-004

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
Fairmont State University and West Liberty University
CFDA Numbers 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
84.408, 93.264, 93.342, 93.364, and 93.925
Partially Resolved
While certain colleges/universities identified in the prior year finding
resolved this matter, New River Community and Technical College had
a finding in the current year. This finding is only partially resolved
because each university/college is only responsible for their own
internal controls and the updated controls have not been implemented
at the above institutions. See current year finding 2018-009 and the
related corrective action plan.
Fairmont State University (FSU) response
Resolved
Corrective action taken at this institution for FY 2018.
West Liberty University (WLU) response
Resolved
Corrective action taken at this institution for FY 2018.
New River Community and Technical College (New River)
response
New River has made the internal control correction that the preparer
and the reviewer of the SEFA will not be the same person.

137

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-005

SPECIAL TESTS AND PROVISIONS – RETURN OF TITLE IV
FUNDS
West Virginia State University and Mountwest Community and
Technical College
CFDA Numbers 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
84.408, 93.264, 93.342, 93.364, and 93.925
Resolved
Corrective action taken for FY 2018.

2017-006
2016-008
2015-015
2014-011
2013-028
2012-43
2012-47
2012-49
2011-22

SPECIAL TESTS AND PROVISIONS – ENROLLMENT
REPORTING
Northern Community and Technical College, Shepherd
University, West Liberty University, and West Virginia
University - Parkersburg
CFDA Numbers 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
84.408, 93.264, 93.342, 93.364, and 93.925
Partially Resolved
While Northern Community and Technical College and Shepherd
University identified in the prior year finding resolved this matter,
West Liberty University, Fairmont State University, Pierpont
Community and Technical College, West Virginia State University,
and West Virginia University at Parkersburg had a finding in the
current year. This finding is only partially resolved because each
university/college is only responsible for their own internal controls
and the updated controls have not been implemented at the above
institutions. See current year finding 2018-012 and the related
corrective action plan.
West Virginia Northern Community and Technical College
(Northern)
Resolved
Corrective action taken at this institution for FY 2018.

138

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
Shepherd University (Shepherd) response
Resolved
Corrective action taken at this institution for FY 2018.
West Liberty University (West Liberty) response
In FY 2019, West Liberty has updated the reporting to all graduated
students within 20 days through Student Clearinghouse to meet all
federal requirements. To increase accuracy in reporting, West Liberty
has also started manually checking graduated students in National
Student Loan Data System (NSLDS) on day 25 to ensure the federal
regulation on reporting for graduates is met.
West Virginia University – Parkersburg (WVUP) response
WVUP acknowledges the enrollment verification process lacked
sufficient documentation for the auditors to verify the review had been
conducted. In response to this finding, WVUP has modified the policy
and procedures to require the financial aid staff to review all
enrollment report files submitted to the National Clearinghouse by
records staff for accuracy and completeness no less than every 30 days.
In addition, WVUP will create a routine form so that staff involved in
review and verification process can sign off and date when the process
has been completed.
2017-007
2016-006

SPECIAL TESTS AND PROVISIONS – BORROWER DATA
TRANSMISSION AND RECONCILIATION
Concord University (Concord)
CFDA Numbers 84.007, 84.033, 84.038, 84.063, 84.268, 84.379,
84.408, 93.264, 93.342, 93.364, and 93.925
Partially Resolved
While certain colleges/universities identified in the prior year finding
resolved this matter, West Liberty University and West Virginia
University at Parkersburg had a finding in the current year. This
finding is only partially resolved because each university/college is only
responsible for their own internal controls and the updated controls

139

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
have not been implemented at the above institutions. See current year
finding 2018-013 and the related corrective action plan.
Concord response
Resolved
Corrective action taken at this institution for FY 2018.
West Liberty University (West Liberty) response
In October 2018, West Liberty was informed of the internal controls
required over the reconciliation process. At that time, one counselor
was responsible for pulling in files from COD and Banner to complete
all reconciliation requirements. All loans and grants were updated and
documented with the counselor. In October 2018, West Liberty
implemented policies and procedures whereby a counselor is still
completing the reconciliation process, but the Director of Financial Aid
is reviewing all reconciliations for completion as well as spot checking
updates and monthly balances.
West Virginia University at Parkersburg (WVUP) response
WVUP performs a proper reconciliation of the Direct Loan School
Account Statement to the amounts disbursed to students. However,
WVUP agrees that written policies and procedures need to be
developed to ensure compliance with this requirement. Therefore,
WVUP Financial Aid officials are in the process of writing and
implementing new policies and procedures for the Direct Loan
implementation process, including the usage of the SAS reports in a
monthly reconciliation process. These policies and procedures will be
effective for the spring 2019 semester. WVUP will utilize the Direct
Loan Reconciliation participant guide provided by the Department of
Education to ensure that policies and procedures are compliant. The
new policy will include the utilization of a routine form so that staff
involved in the review and verification process can sign off and date
when the process is complete.

140

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-008
2016-012
2015-018

ELIGIBILITY
Division of Rehabilitation Services (DRS)
CFDA Number 84.126
Partially Resolved
DRS will continue to review and strengthen training and procedures
around eligibility timeframes and form completion, as well as continue
to remind clients they have a shared responsibility to follow through
and remain in contact with their counselor. See current year finding
2018-014.

2017-009

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
Division of Rehabilitation Services (DRS)
CFDA Number 84.126
Resolved
Corrective action taken for FY 2018.

2017-010
2016-016
2015-024
2014-018
2013-036
2012-56
2011-44
2010-41

SPECIAL TESTS AND PROVISIONS - CHILD SUPPORT NONCOOPERATION, PENALTY FOR REFUSAL TO WORK, AND
ADULT CUSTODIAL PARENT OF CHILD UNDER SIX WHEN
CHILD CARE NOT AVAILABLE
Department of Health and Human Resources (DHHR)
CFDA Number 93.558
Partially Resolved
The DHHR Bureau for Children and Families (BCF) maintains a log of
instances in which a supervisor approves his or her own sanction. The
BCF Policy Unit periodically reviews the log to ensure the sanctions
are reasonable; are applied in accordance with the policies and
procedures currently in place within the BCF surrounding the issuance
and removal of sanctions, as outlined within the West Virginia Income
Maintenance Manual; and are documented within the Recipient
Automated Payment Information Data System (RAPIDS). To improve
upon the log, the BCF Policy Unit will add documentation for each
approval and denial, which will include case records, emails, memos to

141

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
the file, and other documents scanned by the Family Support
Specialist and/or Family Support Supervisor.
The BCF Policy Unit will also review the current policy surrounding
the issuance and removal of sanctions and will update the policy for
clarity if deemed necessary, particularly in relation to the need to
maintain documentation that the policy is operating effectively (i.e.,
maintain documentation surrounding all steps of the sanction process).
The BCF Policy unit will then work with the BCF Division of Training
to review the online Blackboard course surrounding the issuance and
removal of sanctions, will update the course if necessary, and will
ensure that all Family Support Specialists and Family Support
Supervisors are current with their training. Finally, as an additional
level of control, the BCF Policy Unit will create a Sanction Desk Guide
for distribution to all WV WORKS field staff, including but not limited
to the Family Support Specialists and Family Support Supervisors. See
current year finding 2018-019.
2017-011
2016-018
2015-026
2014-021
2013-037
2012-57
2011-50
2010-46
2009-48
2008-59
2007-59
2006-43
2005-50

ALLOWABILITY AND ELIGIBILITY
Department of Health and Human Resources (DHHR)
CFDA Number 93.568
Resolved

Corrective action taken for FY 2018.

142

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-012

REPORTING DOCUMENTATION
Department of Health and Human Resources (DHHR)
CFDA Number 93.568
Resolved
Corrective action taken for FY 2018.

2017-013

DISASTER RECOVERY PLAN
Department of Health and Human Resources (DHHR)
CFDA Numbers 93.575 and 93.596
Resolved
Corrective action taken for FY 2018.

2017-014
2016-021

SPECIAL TESTS AND PROVISIONS – FRAUD DETECTION
AND REPAYMENT
Department of Health and Human Resources (DHHR)
CFDA Numbers 93.575 and 93.596
Partially Resolved
Corrective action was taken in September 2018. To address the
finding, the DHHR Bureau for Children and Families (BCF) developed
a new tracking tool, the purpose of which is to ensure, among other
things, that all fraudulent claims are identified in the appropriate
fiscal year. More specifically, the new tracking tool will ensure that all
fraudulent payments identified in a fiscal year are included within the
population provided to the State’s independent auditors, irrespective of
whether any repayments have been received and added to the
expenses claimed for the fiscal year. The DHHR BCF transmitted the
new tracking tool to the Resource and Referral Agencies on August 14,
2018, via email. To account for the tracking tool within policy, the
Division of Early Care and Education also updated Section 2.3
(Operational and Administrative Requirements) of the Policy and
Procedure Manual for Child Care Resource and Referral Services on
September 21, 2018. See current year finding 2018-022.

143

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-015
2016-022
2015-029
2014-024
2013-040
2012-59

ELIGIBILITY DOCUMENTATION
Department of Health and Human Resources (DHHR)
CFDA Number 93.659
Partially Resolved

The DHHR Bureau for Children and Families developed a revised
Adoption Subsidy and Services Standard Operating Procedure (SOP)
and distributed it on February 14, 2018, to field staff. The procedure
focuses on the steps field staff should be taking to ensure subsidy
payments and medical cards are entered promptly after an adoption
occurs. Furthermore, the procedure discusses the steps that need to be
taken to finalize an adoption record, what items are needed in the
record, and how to send this completed record to the state office.
Finally, the procedure discusses actions the state office will take
should the adoption record be missing information.
The
implementation of the procedure was March 1, 2018.
The issues regarding signatures being obtained prior to parental
relinquishment is a training topic that will be discussed and
implemented in the Blackboard trainings. While the past errors that
may have occurred with documentation cannot be fixed, strides have
been made to ensure that future records are complete and accurate
before going to storage. See current year finding 2018-023.
2017-016

ELIGIBILITY
Department of Health and Human Resources (DHHR)
CFDA Numbers 93.775, 93.777, and 93.778
Resolved
Correction action taken for FY 2018.

144

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-017

CASH MANAGEMENT
School Building Authority (SBA)
CFDA Number 97.036
Partially Resolved
The SBA has developed policies and procedures to ensure that all
advance payments of Federal awards be held in interest-bearing
accounts. In addition, there is a process in place to monitor accrued
interest and remit to the appropriate Department/Agency any amounts
over the cash advances in a timely manner. See current year finding
2018-027.

2017-018
2016-024

SUBRECIPIENT MONITORING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
Partially Resolved
At the end of FY 2018, DHSEM had a FEMA Region III approved
monitoring plan and was in the process of executing the plan. DHSEM
did not have an adequate staff with appropriate training until late
2018 and a formalized policy was not fully implemented until early
2019.
In the last quarter of FY 2018, DHSEM started to assemble an
Internal Review Department. This department will review all policies
and procedures prior to implementation and test them during
production. The department consists of a CPA, a Quality Advisor, a
lead monitor, two monitors, and an internal review/monitoring
business manager. As DHSEM progressed through the end of 2018 and
into 2019, this emerging monitoring team has and will continue to
enable process changes and will help complete the required monitoring
steps to ensure compliance. See current year finding 2018-029.

145

 STATE OF WEST VIRGINIA
DEPARTMENT OF ADMINISTRATION
Financial Accounting & Reporting Section
2101 Washington Street, East
Charleston, WV 25305

Dave Mullins
Acting Director of Finance
(304) 558-6181

Betsy Chapman
Single Audit Coordinator
(304) 558-4083

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS
FOR THE FISCAL YEAR ENDED JUNE 30, 2018
2017-019

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS
Department of Highways and Division of Homeland Security
and Emergency Management
CFDA Number 97.036
Resolved
Correction action taken for FY 2018.

2017-020

INTERNAL CONTROLS OVER REPORTING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
Resolved
Correction action taken for FY 2018.

2017-021

CASH MANAGEMENT MONITORING FINDING
Division of Homeland Security and Emergency Management
(DHSEM)
CFDA Number 97.036
Resolved
Correction action taken for FY 2018.

146