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WORKFORCE DEVELOPMENT BOARD WORK4WV REGION 1, INC.Non-Profit

EIN: 550780985

UEI: JJLKJL8XF553

Audited by: Suttle & Stalnaker, PLLC

Oversight agency: 17 [Department of Labor]

View federal awards & risk assessment →

Data as of August 28, 2026

WORKFORCE DEVELOPMENT BOARD WORK4WV REGION 1, INC.10 audit years20 findings11 repeat
10
Audit Years
20
Total Findings
11
Repeat Findings
$2.9M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$2,900,373 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 20, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 20, 2026 (21 days from today).

What is a management decision? →
2025-002
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2024-002

During our testing of earmarking, it was noted that for 2 of the 60 transactions tested, management could not provide adequate support that the charge was properly reviewed and approved prior to payment. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure the expenditures of the WIOA Cluster are within the earmarking requirements noted within the Uniform Guidance. Effect: Transactions that were part of the earmarking calculations could have been coded improperly or not met the earmarking requirements due to lack of effective internal controls. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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Full finding narrative

2025-002 - EARMARKING (REPEAT OF PRIOR YEAR FINDINGS 2024-002; 2023-003; 2022-03) Federal Program Information: Federal Agency and Program Name- U.S. Department of Labor WIOA Cluster Federal Assistance Listing Number - 17.258/17.259/ 17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: During our testing of earmarking, it was noted that for 2 of the 60 transactions tested, management could not provide adequate support that the charge was properly reviewed and approved prior to payment. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure the expenditures of the WIOA Cluster are within the earmarking requirements noted within the Uniform Guidance. Effect: Transactions that were part of the earmarking calculations could have been coded improperly or not met the earmarking requirements due to lack of effective internal controls. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2025-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: We recognize that full compliance with the Uniform Guidance earmarking requirements is essential. The Board will implement additional controls and procedures to ensure adherence to these standards. We will strengthen these controls by training personnel on the specific steps required and ensuring they fully understand the compliance requirements. Additionally, we will enhance our monitoring processes to verify that all obligations are properly documented and followed. In addition, we will implement additional controls by including checklists to confirm actions and approvals for accounts payable, account reconciliations, review of the general ledger, review of deposits and journal entries. The referred to actions will be presented monthly via email to the executive committee of the Board.

Prior Finding References

2024-002

About Matching, Level of Effort, Earmarking →
2025-003
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-003

During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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Full finding narrative

2025-003 - REPORTING (REPEAT OF PRIOR YEAR FINDINGS 2024-003, 2023-004; 2022-05) Federal Program Information: Federal Agency and Program Name : U.S. Department of Labor WIOA Cluster Federal Assistance Listing Number - 17.258/17.259/ 17.278 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2025-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board will design and implement enhanced controls to ensure compliance with all reporting requirements by evaluating the existing reporting procedures and work to strengthen controls around preparation, review, and submission. These measures will help ensure that all reports are prepared accurately, reviewed appropriately, and submitted in a timely manner. We will proceed in this manner by training personnel in preparation and review. We will create a checklist so the breakdown in this report can be verified as correct and complete. Reports will not be submitted until these procedures have been completed.

Prior Finding References

2024-003

About Reporting →
2025-004
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCY

During our testing of activities allowed or unallowed, it was noted that for 1 of the 60 nonpayroll items tested, management could not provide adequate support that the charge was properly reviewed and approved prior to payment. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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Full finding narrative

2025-004 - ACTIVITIES ALLOWED OR UNALLOWED Federal Program Information: Federal Agency and Program Name - U.S. Department of Labor WIOA Cluster. Federal Assistance Listing Number - 17.258/17.259/ 17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: During our testing of activities allowed or unallowed, it was noted that for 1 of the 60 nonpayroll items tested, management could not provide adequate support that the charge was properly reviewed and approved prior to payment. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $2,843,125 for the year ended June 30, 2025. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2025-004 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board will evaluate existing review and approval processes for federal program charges and implement appropriate controls to ensure all expenditures are thoroughly reviewed, properly authorized, and fully supported before payment is made. As part of the review of charges, a daily review of invoices will be implemented to ensure that all invoices coded to WIOA are allowable costs. The Board’s allowable costs are reviewed by three members: Fiscal Coordinator, Fiscal Manager and Executive Director. These are reviewed and approved by each before the costs are paid. Evidence of these allowable costs will have reviewer’s initials and date reviewed on the bills/invoices themselves and a checklist with signatures that they have reviewed these.

About Activities Allowed or Unallowed →

FY 2024-06-30

$4,117,263 federal awards expended

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

2024-002
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2023-003

Per discussion with management, there was no formal earmarking calculation tracked and performed by the Board during fiscal year 2024. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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Full finding narrative

2024-002 EARMARKING (REPEAT OF PRIOR YEAR FINDINGS 2023-003; 2022-03) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Local Areas: (1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within state allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. (2) The amount that may be spent on incumbent worker training may not exceed 20 percent of the amount of the combined total of federal funds allocated to local areas to carry out the Adult and Dislocated Worker programs for a program year (20 CFR section 680.800; Section 134(d)(4), WIOA, 128 Stat. 1535). (3) WIOA authorizes workforce investment areas, with the approval of the governor, to transfer up to 100 percent of the Adult Activities funds to Dislocated Workers Activities, and up to 100 percent of Dislocated Workers Activities funds to Adult Activities (Section 133(b)(4), WIOA, 128 Stat. 1518). (4) At the discretion of the local board, not more than 10 percent of the total funds allocated to the local area under section 128(b) and under section 133(b)(2)-(3) may be used to implement a pay-for-performance contract strategy as defined in WIOA Section 3(47) (WIOA Section 129(c)(1)(D) and 134(d)(1)(A)(iii)). Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Youth Activities: (1) A minimum of 75 percent of the Youth Activity funds allocated to states and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). (2) Not less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences (Section 129(c)(4)), WIOA, 128 Stat. 1510). Condition: Per discussion with management, there was no formal earmarking calculation tracked and performed by the Board during fiscal year 2024. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2024-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will be practicing earmarking in several ways. When preparing the MACC report, several indicators are noted before filing the report. For the Youth funding stream, the earmark of the YI/YO of 25% to 75% are checked during the preparation of the Youth Report. Also, Youth Activity has to be 20% of the total Youth Grant (Programs only). If these guidelines are not met, the Board will review these issues with the Youth contractor and find ways to reach these earmarks. Concerning the Adult and DW, the Transitional Jobs cannot be more than 10% of the combined Adult and DW combined funding stream for the Fiscal Year. And the same for IWTs, the number reported for them cannot be more than 20% of the Adult and DW combined funding stream for the Fiscal Year. Also, as part of the reporting process, actual to budget report is included for each funding stream. This earmarks the administrative costs are 10% or less than the total funding amount and determines where our budget is during the Fiscal Year. The above information will be reviewed every month. If this or other earmarking are not being obtained, the Board will consult with Workforce WV with what changes or additions are recommended for transparency.

Prior Finding References

2023-003

About Matching, Level of Effort, Earmarking →
2024-003
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2023-004

During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2024-003 REPORTING (REPEAT OF PRIOR YEAR FINDINGS 2023-004; 2022-05) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Board is required to submit MACC reports to WorkForce WV on a monthly basis. Condition: During our testing of reporting, for all MACC reports selected for testing management could not provide adequate support that the MACC reports were properly reviewed and approved prior to being submitted. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster were reviewed and approved prior to submission. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2024-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: As of today, all the reporting to the State is in a timely manner. At present, the Board is working on obtaining approval every MACC report internally with either the Executive Director or the Fiscal Coordinator’s initials on a special form created that reflects they reviewed all the documents as backup for the monthly MACC report. In addition, the Board will be submitting all the backup for the reports to an email address set up by Workforce WV so they will receive all the information on the MACC report. The Board is taking further action to train the Fiscal Coordinator on how to prepare this report. This action is taken for them to help review the reports and take over if necessary. This is so repeat of the previous situation, if it happens, it will not interrupt the Board’s flow of reporting.

Prior Finding References

2023-004

About Reporting →
2024-004
Other
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2023-007

During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Further, it was determined that expenses are being split among expired grants as well as active grants in the client accounting software. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: Grant expenditures were not regularly reconciled and allocated to the appropriate grant number based on actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2024-004 ALLOCATION OF GRANT EXPENSES (REPEAT OF PRIOR YEAR FINDINGS 2023-007; 2022-08) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Further, it was determined that expenses are being split among expired grants as well as active grants in the client accounting software. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,060,483 for the year ended June 30, 2024. Cause: Grant expenditures were not regularly reconciled and allocated to the appropriate grant number based on actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2024-004 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board will be moving forward by using consistent effective and cut-off dates for each allocation period. Between the time the allocation period ended and was compared to the time sheets, there were periods the previous month allocations were put in effect anywhere between the 5th and the 15th of the month. This change in procedure will benefit the Board by giving the allocation process a due date for review and approval. By changing the effective and cut-off date this will give the allocations the same period of time every month. This new process will give the Board more consistency. Each grant expenditure is reconciled to the cash request every month. All expenditures with the exception of payroll are actual monthly expenditures. Before they are put on the cash request, the Board will have approval (by both the Executive Director and Fiscal Manager) as allowed cost for either the purchase order or invoice on hand. Payroll is estimated up to 4 weeks ahead including transitional jobs. (We are paid bi-weekly). The following cash request that covers the actual payroll will have the difference between the actual and estimated on the cash request.

Prior Finding References

2023-007

About Other →

FY 2023-06-30

$4,211,142 federal awards expended

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2023-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-002

During our testing of activities allowed or unallowed, for 11 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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Full finding narrative

2023-002 ACTIVITIES ALLOWED OR UNALLOWED (REPEAT OF PRIOR YEAR FINDING 2022-02) Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, for 11 of the 60 nonpayroll items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: Unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board is taking adequate action to review and approve all charges to the federal programs. The Board’s steps have been reviewed with Workforce WV and has approved our procedures. Supporting documentation is kept both in physical and electronic forms. Each check the Board distributes has an approved Purchase Order attached, (if applicable), Invoice, or if it is a monthly recurring charge, statement or bill attached and once the bill is entered into our system and the bill is paid, the check has the Executive Director’s initials and date showing it is approved in our accounting system. Also, if the expenditures are questionable, we will receive approval before submission of the bill from our liaison in the Workforce WV office.

Prior Finding References

2022-002

About Activities Allowed or Unallowed →
2023-003
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-003

Upon inquiry of management, it was noted that the Board did not perform procedures to ensure that the expenditures of the WIOA Cluster were within the earmarking requirements noted in the Uniform Guidance during the fiscal year ended June 30, 2023. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2023-003 EARMARKING (REPEAT OF PRIOR YEAR FINDING 2022-03) Federal Program Information:, Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Local Areas: (1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within state allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. (2) The amount that may be spent on incumbent worker training may not exceed 20 percent of the amount of the combined total of federal funds allocated to local areas to carry out the Adult and Dislocated Worker programs for a program year (20 CFR section 680.800; Section 134(d)(4), WIOA, 128 Stat. 1535). (3) WIOA authorizes workforce investment areas, with the approval of the governor, to transfer up to 100 percent of the Adult Activities funds to Dislocated Workers Activities, and up to 100 percent of Dislocated Workers Activities funds to Adult Activities (Section 133(b)(4), WIOA, 128 Stat. 1518). (4) At the discretion of the local board, not more than 10 percent of the total funds allocated to the local area under section 128(b) and under section 133(b)(2)-(3) may be used to implement a pay-for-performance contract strategy as defined in WIOA Section 3(47) (WIOA Section 129(c)(1)(D) and 134(d)(1)(A)(iii)). (5) As no state has received prior approval for implementation of a PFP contract strategy, no funds from the program years prior to PY 2019 are available for PFP contract strategies or for the accompanying extended disbursement. However, these funds could still be used for other types of performance-based contracting, but the life of those funds remains the normal two-year limit for local WIOA grant funds. Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Youth Activities: (1) A minimum of 75 percent of the Youth Activity funds allocated to states and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). (2) Not less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences (Section 129(c)(4)), WIOA, 128 Stat. 1510). Condition: Upon inquiry of management, it was noted that the Board did not perform procedures to ensure that the expenditures of the WIOA Cluster were within the earmarking requirements noted in the Uniform Guidance during the fiscal year ended June 30, 2023. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will create a spreadsheet that shows the earmarking percentage for each category. The Board will review various reports for each funding stream at month end and record the actual earmarking percentage for each month. With this information, the Board will discuss these percentages at the monthly manager’s meeting, budget meeting and Board of Directors meeting. If a plan of action is needed, a plan of action will be developed. Also, Workforce WV has a software system that takes the expenditures reported for each funding stream, for each month, called the MACC report in which each Region completes a report that will verify which percentages are not in compliance. The Board will be comparing this report to the analysis report from the State.

Prior Finding References

2022-003

About Matching, Level of Effort, Earmarking →
2023-004
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-005

During our testing of reporting, for all ETA-9130 reports selected for testing management could not provide adequate support that the ETA-9130 reports were properly reviewed and approved prior to being submitted. Additionally, the entity made first tier subawards of greater than $30,000, but could not provide supporting documentation that the necessary reports were filed to satisfy the requirements of the Federal Funding Accountability and Transparency Act (FFATA). Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster and FFATA were submitted accurately and in a timely fashion. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2023-004 REPORTING, (REPEAT OF PRIOR YEAR FINDING 2022-05) Federal Program Information:, Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” ETA-9130, Financial Report (OMB No. 1205-0461) – All ETA grantees are required to submit quarterly financial reports for each grant award they receive. Reports are required to be prepared using the specific format and instructions for the applicable program(s); in this case, Workforce Innovation and Opportunity Act instructions for the following: Statewide Adult; Workforce Statewide Youth; Statewide Dislocated Worker; Local Adult; Local Youth; and Local Dislocated Worker. Reports are due 45 days after the end of the reporting quarter. Financial data is required to be reported cumulatively from grant inception through the end of each reporting period. 2 CFR 170 Appendix A, as it relates to reporting for the Federal Funding Accountability and Transparency Act, “unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.” Condition: During our testing of reporting, for all ETA-9130 reports selected for testing management could not provide adequate support that the ETA-9130 reports were properly reviewed and approved prior to being submitted. Additionally, the entity made first tier subawards of greater than $30,000, but could not provide supporting documentation that the necessary reports were filed to satisfy the requirements of the Federal Funding Accountability and Transparency Act (FFATA). Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster and FFATA were submitted accurately and in a timely fashion. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.

Prior Finding References

2022-005

About Reporting →
2023-005
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-006

Upon inquiry of management, the Board did not perform any subrecipient monitoring procedures related to the Board’s grant agreement with its subrecipient for the fiscal year ended June 30, 2023. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023, which included $1,350,121 of expenditures to subrecipients. Cause: Although the Board has policies and procedures in place surrounding the subrecipient monitoring compliance requirements, due to staffing issues during the fiscal year and lack of knowledge of all the federal compliance requirements, no subrecipient monitoring was completed. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2023-005 SUBRECIPIENT MONITORING (REPEAT OF PRIOR YEAR FINDING 2022-06) Federal Program Information:, Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate 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 described in paragraphs (d) and (e) of this section. Condition: Upon inquiry of management, the Board did not perform any subrecipient monitoring procedures related to the Board’s grant agreement with its subrecipient for the fiscal year ended June 30, 2023. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023, which included $1,350,121 of expenditures to subrecipients. Cause: Although the Board has policies and procedures in place surrounding the subrecipient monitoring compliance requirements, due to staffing issues during the fiscal year and lack of knowledge of all the federal compliance requirements, no subrecipient monitoring was completed. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-005 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Action Taken: With the assistance of Workforce WV, the Board met with a private company representative (via Zoom) who made recommendations to the Board for fiscal monitoring of the Board’s subrecipient. A plan is in the process of accomplishing this action for both 21-22 and 22-23 Fiscal Years. The Board is planning on submitting a monitoring report within the next week. This process will be developed, and a six-month monitoring period is being developed to enter into the Board’s policies and procedures as a normal course of action.

Prior Finding References

2022-006

About Subrecipient Monitoring →
2023-006
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-007

During our testing of WIOA participants, it was noted by management that the eligibility determination for Youth Activities is maintained and conducted by the Board’s subrecipient. According to management, there are no procedures performed at the Board to verify the eligibility of Youth Activities participants to ensure that all federal compliance requirements are being adhered to. Additionally, 2 of the 60 individual adult program applications selected for testing were not reviewed by a case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board does not perform any procedures to ensure that the Youth Activities participants meet all the federal compliance requirements for participation in the program. Further, the Board did not review two individual adult program applications for eligibility. Effect: A Youth Activities participant(s)/Adult Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2023-006 ELIGIBILITY (REPEAT OF PRIOR YEAR FINDING 2022-07) Federal Program Information:, Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. Condition: During our testing of WIOA participants, it was noted by management that the eligibility determination for Youth Activities is maintained and conducted by the Board’s subrecipient. According to management, there are no procedures performed at the Board to verify the eligibility of Youth Activities participants to ensure that all federal compliance requirements are being adhered to. Additionally, 2 of the 60 individual adult program applications selected for testing were not reviewed by a case manager. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: The Board does not perform any procedures to ensure that the Youth Activities participants meet all the federal compliance requirements for participation in the program. Further, the Board did not review two individual adult program applications for eligibility. Effect: A Youth Activities participant(s)/Adult Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for the Youth program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth (Youth In or Youth Out) is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison. For the Adult Program, the Board has implemented internal controls to ensure each applicant completes the applications and to determine if they are eligible for the programs the Board offers. Our Business Services Manager reviews each application taken by the Board’s Career Services Coordinator and ensures they are in the correct program by the application.

Prior Finding References

2022-007

About Eligibility →
2023-007
Other
MATERIAL WEAKNESSREPEAT OF 2022-008OTHER MATTERS

During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Further, it was determined that expenses are being split among expired grants as well as active grants in the client accounting software. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: Due to staffing changes during the year, grant expenditures were not regularly reconciled and allocated to the appropriate grant number based on actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2023-007 ALLOCATION OF GRANT EXPENSES (REPEAT OF PRIOR YEAR FINDING 2022-08) Federal Program Information:, Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Further, it was determined that expenses are being split among expired grants as well as active grants in the client accounting software. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $4,165,604 for the year ended June 30, 2023. Cause: Due to staffing changes during the year, grant expenditures were not regularly reconciled and allocated to the appropriate grant number based on actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board has developed a process to correctly allocate expenditures to the correct funding stream. At each month’s end, all employees complete an allocation spreadsheet. When all spreadsheets are completed, approved, and turned in, the Board determines the allocation of payroll and expenditures. Expenditures that occurred in March will be allocated using the allocation chart for February. Also, this procedure is backup for each cash request that is submitted for funding. And, this is reviewed for the reconciliation between the cash request and the Board’s accounting software.

Prior Finding References

2022-008

About Other →

FY 2022-06-30

$3,971,608 federal awards expended

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2022-002
Activities Allowed or Unallowed
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During our testing of activities allowed or unallowed, it was noted that for six of the 60 items tested, management could not provide adequate supporting documentation for the items selected for testing. Additionally, for 20 of the 60 items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: $202,486 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not retain adequate documentation to support the charges to the federal program, and did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Additionally, unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment, and that adequate supporting documentation for all federal program charges is maintained. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-002 ACTIVITIES ALLOWED OR UNALLOWED Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(g) states that costs must “Be adequately documented.” Condition: During our testing of activities allowed or unallowed, it was noted that for six of the 60 items tested, management could not provide adequate supporting documentation for the items selected for testing. Additionally, for 20 of the 60 items tested, management could not provide adequate support that the charges were properly reviewed and approved prior to payment. Questioned Costs: $202,486 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not retain adequate documentation to support the charges to the federal program, and did not demonstrate that proper internal controls are in place and operating effectively to ensure that unallowable charges to the federal program do not occur. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Additionally, unallowable payments to the federal program may have occurred due to the lack of effective internal controls in place. Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment, and that adequate supporting documentation for all federal program charges is maintained. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-002 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment, and that adequate supporting documentation for all federal program charges is maintained. Action Taken: The Board is taking adequate action to review and approve all charges to the federal programs. The Board’s steps have been reviewed with Workforce WV and has been approved our procedures. Supporting documentation is kept both in physical and electronic forms. Each check the Board distributes has an approved purchase order attached, (if applicable), invoice, or if it is a monthly recurring charge, statement or bill attached and once the bill is entered into our system and the bill is paid, the check has the Executive Director’s initials and date showing it is approved in our accounting system. Also, if the expenditures are questionable, we will receive approval before submission of the bill from our liaison in the Workforce WV office.

About Activities Allowed or Unallowed →
2022-003
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINION

Upon inquiry of management, it was noted that the Board did not perform procedures to ensure that the expenditures of the WIOA Cluster were within the earmarking requirements noted in the Uniform Guidance during the fiscal year ended June 30, 2022. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-003 EARMARKING Federal Program Information:, Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Local Areas: (1) A local area may expend no more than 10 percent of the Adult, Dislocated Worker, and Youth Activities funds allocated to the local area under Sections 128(b) (WIOA, 128 Stat. 1502) and 133(b) (WIOA, 128 Stat. 1516) for within state allocations. The funds provided for administrative costs by one of the three fund sources (Adult, Dislocated Worker, Youth Activities) can be used for administrative costs of the other two sources. (2) The amount that may be spent on incumbent worker training may not exceed 20 percent of the amount of the combined total of federal funds allocated to local areas to carry out the Adult and Dislocated Worker programs for a program year (20 CFR section 680.800; Section 134(d)(4), WIOA, 128 Stat. 1535). (3) WIOA authorizes workforce investment areas, with the approval of the governor, to transfer up to 100 percent of the Adult Activities funds to Dislocated Workers Activities, and up to 100 percent of Dislocated Workers Activities funds to Adult Activities (Section 133(b)(4), WIOA, 128 Stat. 1518). (4) At the discretion of the local board, not more than 10 percent of the total funds allocated to the local area under section 128(b) and under section 133(b)(2)-(3) may be used to implement a pay-for-performance contract strategy as defined in WIOA Section 3(47) (WIOA Section 129(c)(1)(D) and 134(d)(1)(A)(iii)). (5) As no state has received prior approval for implementation of a PFP contract strategy, no funds from the program years prior to PY 2019 are available for PFP contract strategies or for the accompanying extended disbursement. However, these funds could still be used for other types of performance-based contracting, but the life of those funds remains the normal two-year limit for local WIOA grant funds. Per the provisions stated in the Uniform Guidance under the WIOA Cluster for Youth Activities: (1) A minimum of 75 percent of the Youth Activity funds allocated to states and local areas, except for the local area expenditures for administration, must be used to provide services to out-of-school youth (Section 129(a)(4)(A), WIOA, 128 Stat. 1506). (2) Not less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences (Section 129(c)(4)), WIOA, 128 Stat. 1510). Condition: Upon inquiry of management, it was noted that the Board did not perform procedures to ensure that the expenditures of the WIOA Cluster were within the earmarking requirements noted in the Uniform Guidance during the fiscal year ended June 30, 2022. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not perform the appropriate procedures to verify that the expenditures of the WIOA Cluster were within the earmarking requirements noted within the Uniform Guidance. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will create a spreadsheet that shows the earmarking percentage for each category. The Board will review various reports for each funding stream at month end and record the actual earmarking percentage for each month. With this information, the Board will discuss these percentages at the monthly manager’s meeting, budget meeting and Board of Directors meeting. If a plan of action is needed, a plan of action will be developed. Also, Workforce WV has a software system that takes the expenditures reported for each funding stream, for each month, called the MACC report in which each Region completes a report that will verify which percentages are not in compliance.

About Matching, Level of Effort, Earmarking →
2022-004
Period of Performance
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 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.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-004 Period of Performance U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Action Taken: For each accounting procedure, internal controls have been put in place. The Board’s payroll processing goes through three levels of approval before it is processed. The expenditures process goes through three levels of approval before the bill is paid. The Board is verifying that each report or process is approved by at least three levels of approval and within a timely manner. Expenditure checks are issued every two weeks. The approval of these checks is also approved by an officer of the Board of Directors. Any out of the ordinary practices have both the approval of the Executive Director and an officer of the Board of Directors. With the past issues of this Board, the Board added an internal control for the sake of period of performance, for reports that are submitted to Workforce WV. In addition, these reports will be reviewed and approved by one of the managers of the Board within the time the report is due.

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2022-005
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

Upon inquiry of management, no supporting documentation could be provided that the ETA-9130, Financial Reports (OMB No. 1205-0461) and the WIOA Participant Individual Record Layout (OMB No. 1205-0526) performance reports required by the WIOA Cluster were prepared and submitted. Additionally, the entity made first tier subawards of greater than $30,000, but could not provide supporting documentation that the necessary reports were filed to satisfy the requirements of the Federal Funding Accountability and Transparency Act (FFATA). Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster and FFATA were submitted accurately and in a timely fashion. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-005 REPORTING Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” ETA-9130, Financial Report (OMB No. 1205-0461) – All ETA grantees are required to submit quarterly financial reports for each grant award they receive. Reports are required to be prepared using the specific format and instructions for the applicable program(s); in this case, Workforce Innovation and Opportunity Act instructions for the following: Statewide Adult; Workforce Statewide Youth; Statewide Dislocated Worker; Local Adult; Local Youth; and Local Dislocated Worker. Reports are due 45 days after the end of the reporting quarter. Financial data is required to be reported cumulatively from grant inception through the end of each reporting period. WIOA Participant Individual Record Layout (PIRL) (OMB No. 1205-0526) - The report is used to report services, activities, and outcomes of service for all job seekers and veterans. The WIOA Adult, Dislocated Worker, and Youth Programs are responsible for reporting common WIOA performance indicators. 2 CFR 170 Appendix A, as it relates to reporting for the Federal Funding Accountability and Transparency Act, “unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency as noted in paragraph e. no later than the end of the month following the month in which the obligation was made.” Condition: Upon inquiry of management, no supporting documentation could be provided that the ETA-9130, Financial Reports (OMB No. 1205-0461) and the WIOA Participant Individual Record Layout (OMB No. 1205-0526) performance reports required by the WIOA Cluster were prepared and submitted. Additionally, the entity made first tier subawards of greater than $30,000, but could not provide supporting documentation that the necessary reports were filed to satisfy the requirements of the Federal Funding Accountability and Transparency Act (FFATA). Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have adequate policies and internal controls in place to ensure that all required reports for the WIOA Cluster and FFATA were submitted accurately and in a timely fashion. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-005 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of period of performance and reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.

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2022-006
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

Upon inquiry of management, the Board did not perform any subrecipient monitoring procedures related to the Board’s grant agreement with its subrecipient for the fiscal year ended June 30, 2022. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022, which included $1,390,746 of expenditures to subrecipients. Cause: Although the Board has policies and procedures in place surrounding the subrecipient monitoring compliance requirements, due to staffing issues during the fiscal year and lack of knowledge of all the federal compliance requirements, no subrecipient monitoring was completed. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-006 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that all pass-through entities must: Evaluate 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 described in paragraphs (d) and (e) of this section. Condition: Upon inquiry of management, the Board did not perform any subrecipient monitoring procedures related to the Board’s grant agreement with its subrecipient for the fiscal year ended June 30, 2022. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022, which included $1,390,746 of expenditures to subrecipients. Cause: Although the Board has policies and procedures in place surrounding the subrecipient monitoring compliance requirements, due to staffing issues during the fiscal year and lack of knowledge of all the federal compliance requirements, no subrecipient monitoring was completed. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-006 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Action Taken: With the assistance of Workforce WV, the Board met with a private company representative (via Zoom) who made recommendations to the Board for fiscal monitoring of the Board’s subrecipient. A plan is in the process of accomplishing this action for both 21-22 and 22-23 Fiscal Years. The Board is planning on submitting a monitoring report within the next week. This process will be developed, and a six-month monitoring period is being developed to enter into the Board’s policies and procedures as a normal course of action.

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2022-007
Eligibility
MATERIAL WEAKNESSMODIFIED OPINION

During our testing of WIOA participants, it was noted by management that the eligibility determination for Youth Activities is maintained and conducted by the Board’s subrecipient. According to management, there are no procedures performed at the Board to verify the eligibility of Youth Activities participants to ensure that all federal compliance requirements are being adhered to. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board does not perform any procedures to ensure that the Youth Activities participants meet all the federal compliance requirements for participation in the program. Effect: A Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-007 ELIGIBILITY Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of-school youth or an in-school youth (Section 129(a)(1), WIOA, 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. Condition: During our testing of WIOA participants, it was noted by management that the eligibility determination for Youth Activities is maintained and conducted by the Board’s subrecipient. According to management, there are no procedures performed at the Board to verify the eligibility of Youth Activities participants to ensure that all federal compliance requirements are being adhered to. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board does not perform any procedures to ensure that the Youth Activities participants meet all the federal compliance requirements for participation in the program. Effect: A Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-007 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for either the Youth In or the Youth Out program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison.

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2022-008
Other
MATERIAL WEAKNESSOTHER MATTERS

During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The former Fiscal Manager estimated expenses for reimbursement requests and allocated expenses to the grants of the WIOA Cluster Assistance Listing numbers. When the reimbursements were received, the estimated expenses were not reconciled to the actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

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2022-008 ALLOCATION OF GRANT EXPENSES Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster, 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: During our testing of WIOA Cluster expenditures, it was noted that the Board did not regularly reconcile expenditures to the appropriate assistance listing numbers within the WIOA Cluster during the year. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The former Fiscal Manager estimated expenses for reimbursement requests and allocated expenses to the grants of the WIOA Cluster Assistance Listing numbers. When the reimbursements were received, the estimated expenses were not reconciled to the actual expenses. Effect: Expenses were not properly allocated to the correct Assistance Listing number within the WIOA cluster. Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2022-008 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board has developed a process to correctly allocate expenditures to the correct funding stream. At each month’s end, all employees complete an allocation spreadsheet. When all spreadsheets are completed, approved, and turned in, the Board determines the allocation of payroll and expenditures. Expenditures that occurred in March will be allocated using the allocation chart for February. Also, this procedure is backup for each cash request that is submitted for funding. Also, this is reviewed for the reconciliation between the cash request and the Board’s accounting software.

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FY 2021-06-30

$3,953,719 federal awards expended

FAC accepted this audit on September 20, 2023 — management decision was due March 20, 2024.

2021-001
Cash Management
MATERIAL WEAKNESS

Allocation of expenses between the above listed CFDA numbers was not regularly reconciled throughout the year. Effect: The Organization improperly requested funds for expenses during the year. Cause: The former finance manager estimated expenses for reimbursement requests and allocated expenses to each grant. When the reimbursements were received, the estimated expenses were not reconciled to the actual expenses. Questioned Costs: None Recommendation: Reimbursements should be for actual expenses, or the estimated and actual expenses should be reconciled. Management?s Response: Noted in the auditee?s Corrective Action Plan.

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Section III ? Findings and Questioned Costs ? Major Federal Program Audit 2021-001: Allocation of Grant Expenses ? Schedule of Expenditures of Federal Awards U.S. Department of Labor Passed Through West Virginia Development Office WIOA Cluster CFDA #17.259, 17.278, 17.258 Criteria: Good internal controls require obtaining proper authorization, approval, and allocation for all transactions. Proper documentation should be maintained to support all transactions. Condition: Allocation of expenses between the above listed CFDA numbers was not regularly reconciled throughout the year. Effect: The Organization improperly requested funds for expenses during the year. Cause: The former finance manager estimated expenses for reimbursement requests and allocated expenses to each grant. When the reimbursements were received, the estimated expenses were not reconciled to the actual expenses. Questioned Costs: None Recommendation: Reimbursements should be for actual expenses, or the estimated and actual expenses should be reconciled. Management?s Response: Noted in the auditee?s Corrective Action Plan.

Corrective Action Plan

WIB Region 1 corrective action is to reconciliation all the Cash Requests with its accounting software "Quick Books" non-profit.

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FY 2020-06-30

LOW-RISK AUDITEE$3,447,724 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$3,039,709 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 1, 2020 — management decision was due October 1, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$3,475,690 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 28, 2018 — management decision was due May 28, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$2,964,661 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 21, 2018 — management decision was due August 21, 2018.

FY 2016-06-30

$2,746,605 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 13, 2017 — management decision was due August 13, 2017.

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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