10 Program, Fiscal Monitoring, and Audit, 2605(b)(10) - Assurance 10

10.1. How do you ensure good fiscal accounting and tracking of funds? Federal funds awarded to West Virginia are committed and identified in WV (Our Advanced Solution with Integrated Systems) OASIS. LIHEAP Customer payments are also entered into OASIS and daily payments are tracked and monitored to determine that expenditure does not exceed the amounts that are awarded. The state's People Access To Help (PATH) is the benefits issuance processing program that workers access to determine customer eligibility for LIHEAP. The system provides individual approvals and daily batch approvals which allow for dual controls. Benefits are approved in PATH and can be sent to OASIS for payments to utility companies, bulk fuel vendors and to clients. Weatherization funds are not transferred to other state agencies. The West Virginia Department of Economic Development (WVDED) runs the Weatherization program for West Virginia. The WVDED is allotted 15% of the total grant funds. The DoHS Finance department tracks all funding spent for this grant. This includes refunds, weatherization, administration, heating assistance, crisis, and carryover. 10.1a Provide your definitions of the following: Obligation Obligations The OSA Finance defines “financial obligations” to mean orders placed for property and services, contracts and subawards executed, and similar transactions that require payment by the Departments under a Federal award that will result in expenditures by the Departments under a Federal award. (The OSA Finance recognizes that expenditures are not always contemporaneous with the financial obligation. Rather, an obligation will often require a future – but not immediate – expenditure or outlay of funds.) “Unliquidated financial obligation” means financial obligations incurred by the Departments but not paid (liquidated) for financial reports prepared on a cash basis. For reports prepared on an accrual basis, unliquidated financial obligations are financial obligations incurred by the Departments but for which expenditures have not been recorded. “Unobligated balance” means the amount of funds under a Federal award that the Departments have not obligated. The amount is computed by subtracting the cumulative amount of the applicable Department’s unliquidated financial obligations and expenditures under the Federal award from the cumulative amount of funds the Federal agency authorized the Department to obligate. “Budget period” means the time interval from the start date of a funded portion of an award to the end date of that funded portion, during which the Departments are authorized to incur financial obligations of the funds awarded, including any funds carried forward or other revisions pursuant to 2 CFR 200.308 (titled, “Revision of budget and program plans”). The “period of performance” is the time interval between the start and end date of a Federal award, which may include one or more budget periods. A “no-cost extension” [of the period of performance] is an extension of time that does not require the obligation of additional Federal funds. When executing subawards and subsequently reporting on first-tier subawards within the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) at http://www.fsrs.gov, the OSA Finance determines when an action constituting a legal obligation of the subaward has occurred, which begins the reporting clock. (The OSA Finance recognizes that it must use some discretion and reasonable judgement to determine when an action constituting a legal obligation of the subaward has occurred, which is per the U.S. Office of Management and Budget.) For the purposes of closeout, OSA Finance, on behalf of the Departments, liquidates all financial obligations incurred under a Federal award no later than 120 calendar days after the conclusion of the period of performance, unless the Federal agency approves an extension of the due date. Financial management standards within the Departments, OSA Finance, and the State as a whole require the maintenance of records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records are supported by source documentation. Expenditures Expenditures For purposes of Federal awards and other financial assistance received by the West Virginia Department of Health, Department of Health Facilities, and Department of Human Services (hereinafter referred to as “Departments”), the Office of Shared Administration, Office of Finance (hereinafter referred to as “OSA Finance”) defines the word “expenditures” to mean charges made by the Departments to a project or program for which a Federal award and other financial assistance (e.g., State-appropriated funds) is received. [Note: Per Federal regulations and financial management standards, the charges may be reported on a cash or accrual basis as long as the methodology is disclosed and consistently applied.] For reports prepared on a cash basis, expenditures are the sum of: Cash disbursements for direct charges for property and services. • The amount of indirect expense charged. • The value of third-party in-kind contributions applied. • The amount of cash advance payments and payments made to subrecipients. • For reports prepared on an accrual basis, expenditures are the sum of: Cash disbursements for direct charges for property and services. • The amount of indirect expenses incurred. • The value of third-party in-kind contributions applied. • The net increase or decrease in the amounts owed by the Departments for goods and other property received; services performed by employees, contractors, subrecipients, and other payees; and programs for which no current services or performance are required, such as annuities, insurance claims, or other benefit payments. • Per 2 CFR 200.34, “Expenditures means charges made by a non-Federal entity to a project or program for which a Federal award was received. The charges may be reported on a cash or accrual basis, as long as the methodology is disclosed and is consistently applied.” Expenditure timeframe 2 CFR 200.343; liquidates all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance unless the Federal awarding agency authorizes an extension; and promptly refunds any balances of unobligated cash that the Federal awarding agency paid in advance or paid and that is not authorized to be retained by the DHHR for use in other projects. Administrative costs Costs associated with taking applications, determining eligibility and benefit levels, and monitoring the assistance provided. Audit Process 10.2. Is your LIHEAP program audited annually under the Single Audit Act and OMB Circular A - 133? Yes No 10.2a - if yes, describe your auditor selection process. West Virginia uses an accounting firm to conduct our LIHEAP audits. Internal communications reach out to LIHEAP policy for needed information. A random sample of cases are chosen each year for audit. 10.3. Describe any audit findings of the grant recipient (i.e. State/Tribe/Territory) rising to the level of material weakness or reportable condition cited in the single audits, inspector general reviews, or other government agency reviews from the most recently audited fiscal year. No Findings Finding Type Brief Summary Resolved? Action Taken Benefit Error- Management indicated that the errors were due to the benefit tables not being properly updated within the People's Access To Help (PATH) system to properly calculate the recipients benefits during the months of May and June 1 financial Yes training changes 2023. This was due to insufficient oversight to ensure the table amounts were correct and the benefits were calculating properly based on the eligible recipients household size, income, and source of energy. The LIHEAP policy staff within the DoHS, Bureau for Family Assistance (BFA), have worked with the People's Access To Help (PATH)System team to confirm that the benefit table has been accurately entered into the PATH system for fiscal year 2024. The LIHEAP policy staff will continue to review the work of the PATH team to ensure that the benefit table has been accurately entered prior to the opening of LIHEAP application intake annually. 10.4. Audits of Local Administering Agencies What types of annual audit requirements do you have in place for local administering agencies/district offices? Select all that apply. Local agencies/district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Local agencies/district offices are required to have an annual audit (other than A-133) Local agencies/district offices' A-133 or other independent audits are reviewed by Grant recipient as part of compliance process. Grant recipient conducts fiscal and program monitoring of local agencies/district offices Local agencies and district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Compliance Monitoring 10.5. Describe your monitoring process for compliance at each level below. Check all that apply. Grant recipients have a policy in place for appropriate separation of duties and internal controls. Internal program review Departmental oversight Secondary review of invoices and payments Other program review mechanisms are in place. Describe: Other program review mechanisms are in place. Describe: West Virginia has a program called Rushmore that caseworkers enter LIHEAP cases into a system including the clients income information, utility information, and all other needed information and the supervisor must review the case before case worker can approve the case. This helps prevent errors and helps determine caseworker’s issues when processing these applications. LIHEAP review elements are applications, forms, income, utility bills, vendor/voucher, bulk fuel, timeliness, incorrect approval/ denial/amounts, case comments, and notices. Also LIHEAP Coordinator Pulls case to review as well to look for errors. Local Administering Agencies/District Offices: On - site evaluation Annual program review Monitoring through central database Desk reviews Client File Testing/Sampling Other program review mechanisms are in place. Describe: There is a Statewide Single Audit that is completed each year. There is a sampling of LIHEAP cases that are reviewed each year. West Virginia has a data monitoring system that helps determine what are the most common errors in cases. This system is called Rushmore. For Fiscal year 2025 LIHEAP has been added to the system. Supervisors review LIHEAP applications that are being processed by caseworkers and report all information into the database. With this information we can determine what part of training we need to improve on. West Virginia LIHEAP coordinator also pulls LIHEAP cases from each county and adds them to the Rushmore monitoring system for review for potential errors and to see what additional training assistance is needed. 10.6 Explain, or attach a copy of your local agency monitoring schedule and protocol. West Virginia has a LIHEAP Monitoring Plan: West Virginia LIHEAP monitors WV Department of Economic Development, that covers Repair or Replacement Program and Weatherization. Monthly meetings are held, office visits and site visits are also completed. 10.7. Describe how you select local agencies for monitoring reviews. Attach a risk assessment if subrecipients are utilized. Site Visits: A large sample is pulled for the Statewide Single Audit. Also to prevent issues the LIHEAP Coordinator holds and month/weekly meetings. A sample of the LIHEAP applications are taken from all three regions to ensure that there is not a trend or an issue with the local DoHS offices in the application process. The monitoring reviews are done yearly based on the schedule of our auditors who complete the Statewide Single Audit. Desk Reviews: The LIHEAP Coordinator for West Virginia pulls 2 cases from each county to ensure workers are processing LIHEAP correctly and it is all documented on Rushmore. A large sample is pulled for the Statewide Single Audit to ensure that the LIHEAP applications are not all coming from the same local DoHS office and to ensure that all processes and procedures are consistent 10.8. How often is each local agency monitored? Please attach a monitoring schedule if one has been developed. Annually 10.9. How many local agencies are currently on corrective action plans? 0 If any of the above questions require further explanation or clarification that could not be made in the fields provided, attach a document with said explanation here.