UNITED STATES 

ELECTION ASSISTANCE COMMISSION 

OFFICE OF INSPECTOR GENERAL 

Administration of Payments Received 

Under the Help America Vote Act by 

the West Virginia Secretary of State

Report No. E-HP-WV-13-20
 

 

 

 

 

 

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OFFICE OF THE INSPECTOR GENERAL 

US ELECTION ASSISTANCE COMMISSION 

633 3RD STREET, NW, SUITE 200 

WASHINGTON, DC 20001 

Memorandum 

To: Mona Harrington 

Executive Director 

From: Patricia L. Layfield 

Patricia L. Layfield 

Inspector General 

Date: February 3, 2021 

Subject: Final Performance Audit Report - Administration of Payments Received Under the 

Help America Vote Act by the West Virginia Secretary of State (Assignment Number 

E-HP-WV-13-20) 

The Office of Inspector General (OIG) engaged McBride, Lock & Associates, LLC (MLA), an 

independent certified public accounting firm, to audit the administration of payments received 

under the Help America Vote Act (HAVA) by the West Virginia Secretary of State (WVSOS). The 

audit scope covered the grant funds received and disbursed by the WVSOS, from June 29, 2018, 

through September 30, 2019. The $3.6 million in funds paid to the WVSOS represented West 

Virginia’s share of the appropriation of $380 million under the Consolidated Appropriations Act 

of 2018 (P.L. 115-151). WVSOS expended approximately $3.8 million of the HAVA funds 

(including state matching funds and program income) during the period covered by the audit. 

Results of Audit 

Based on the audit procedures performed, MLA concluded that, except for the matters 

discussed below, the Office accounted for and expended the HAVA funds in accordance with 

applicable requirements, properly accounted for and controlled property purchased, and used 

the funds in a manner consistent with the budget plan for the period from June 29, 2018 

through September 30, 2019. However, MLA noted the following exceptions: 

1. The Office submitted financial reports for Election Security funds that did not agree to 

the underlying accounting records. 

Find us here: EAC OIG Website 

Toll free: 1- 866-552-0004 | e-mail: eacoig@eac.gov 
 

 

 

 

 

 

 

 

2. The Office’s monitoring of subrecipients did not ensure that property records were 

maintained in compliance with Federal grant regulations promulgated by the Office of 

Management and Budget (2 CFR 200). 

The Office generally agreed with the report’s findings and recommendations. The EAC 

responded on January 6, 2021 and stated that they are reviewing the Office’s planned actions. 

We would appreciate being kept informed of the actions taken on our recommendations as we 

will track the status of their implementation. Please respond in writing concerning the status of 

your audit follow-up on the findings and recommendation included in this report by March 15, 

2021. Your response should include information on actions taken or planned, targeted 

completion dates, and titles of officials responsible for implementation. 

Evaluation of MLA’s Audit Performance 

To fulfill our responsibilities under Government Auditing Standards, the Office of Inspector 

General: 

• Reviewed MLA's approach and planning of the audit; 

• Evaluated the qualifications and independence of the auditors; 

• Monitored the progress of the audit at key points; 

• Reviewed MLA’s audit report and selected work products, to ensure compliance with 

Government Auditing Standards; and 

• Coordinated issuance of the audit report. 

MLA is responsible for the attached auditor’s report and the findings and conclusions 

expressed in the report. The work the EAC OIG performed in evaluating MLA’s conduct of the 

audit was not sufficient to support an opinion on the effectiveness of internal control or 

compliance with laws and regulations, thus EAC OIG does not express any opinion on the 

internal controls or compliance of the WVSOS. 

The Inspector General Act of 1978, as amended, requires semiannual reporting to Congress on 

all reports issued, actions taken to implement recommendations, and recommendations that 

have not been implemented. Therefore, we will report the issuance of this audit report in our 

next semiannual report to Congress. The distribution of this report is not restricted and copies 

are available for public inspection. Pursuant to the IG Empowerment Act of 2016, the EAC OIG 

will post this audit report on the OIG website within 3 days of its issuance to EAC management. 

The OIG will also post the report to Oversight.gov. 

If you have any questions regarding this report, please call me at (202) 853-2760. 

cc: Commissioner Benjamin W. Hovland, Chair 

Commissioner Donald L. Palmer, Vice-Chair 

Commissioner Thomas Hicks 

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Commissioner Christy McCormick 

Chuck Flannery, Deputy Secretary & Chief of Staff, Office of the Secretary of State of West 

Virginia 

Attachment 

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McBRIDE, LOCK & ASSOCIATES, LLC 

Certified Public Accountants 

Established 1980 

Performance Audit Report 

Administration of Election Security Payments Received Under the Help 

America Vote Act by the West Virginia Secretary of State 

Prepared for 

The United States Election Assistance Commission (EAC) 

Office of Inspector General 

By 

McBride, Lock & Associates, LLC 

January 2021 

4151 N. Mulberry Drive, Suite 275 p. 816-221-4559 admin@mcbridelock.com 

Kansas City, Missouri 64116 f. 816-221-4563 www.mcbridelock.com 
 

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Performance Audit Report 

Administration of Election Security Payments Received Under the Help 

America Vote Act by the West Virginia Secretary of State 

TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY 1 

BACKGROUND 2 

AUDIT OBJECTIVES 3 

SCOPE AND METHODOLOGY 3 

AUDIT RESULTS 5 

APPENDICES: 

Appendix A-1: Response of the West Virginia Secretary of State to the Draft Report 

Appendix A-2: Response of the U.S. Election Assistance Commission 

to the Draft Report 

Appendix B: Audit Scope and Methodology 

Appendix C: Expenditures by Budget Category and Program Category 

Appendix D: Monetary Impact as of September 30, 2019 
 

 

 

 

 

 

 

 

 

 

 

 

U.S. Election Assistance Commission 

Performance Audit Report 

Administration of Election Security Payments Received Under the Help 

America Vote Act by the West Virginia Secretary of State 

EXECUTIVE SUMMARY 

McBride, Lock & Associates, LLC was engaged by the United States Election Assistance 

Commission (EAC) Office of the Inspector General to conduct a performance audit of the election 

security funds the West Virginia Secretary of State’s Office (Office) received between June 29, 

2018 and September 30, 2019. The objective of the audit was to determine whether the Office used 

payments authorized by Section 101 of the Help America Vote Act of 2002 (the HAVA) in 

accordance with HAVA and applicable requirements; properly accounted for and controlled the 

funds and property purchased with HAVA payments; and used the funds in a manner consistent 

with the budget plan provided to EAC. 

In addition, the Commission requires states to comply with certain financial management 

requirements, specifically: 

• Expend payments in accordance with Federal cost principles established by the Office of 

Management and Budget (OMB) – (2 CFR 200). 

• Submit detailed annual financial reports on the use of Title I payments. 

• Maintain documents and records subject to audit to determine whether payments were used 

in compliance with HAVA. 

We conducted this performance audit in accordance with Generally Accepted Government 

Auditing Standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on the audit objectives. 

Based on the audit procedures performed, except for the matters discussed below, we concluded 

that the Office generally accounted for and expended the Grant funds in accordance with the 

requirements mentioned above for the period from June 29, 2018 through September 30, 2019. 

The exceptions are as follows: 

1. The Office submitted financial reports for Election Security funds that did not agree to the 

underlying accounting records for Federal Share of Expenditures and Total Federal 

Program Income Earned. 

2. The Office’s monitoring of subrecipients did not ensure that property records were 

maintained in compliance with 2 CFR 200. Four of five subrecipients selected for physical 

observation of equipment maintained property records that did not include all information 

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required by 2 CFR 200. All equipment selected from invoices for physical observation 

were determined to exist. 

We have included in this report as Appendix A, the Secretary of State’s written response to the 

draft report. Such response has not been subjected to the audit procedures and, accordingly, we do 

not provide any form of assurance on the appropriateness of the response or the effectiveness of 

the corrective actions described therein. 

BACKGROUND 

The Help America Vote Act of 2002 (HAVA) created the U.S. Election Assistance Commission 

(Commission) to assist States and insular areas (hereinafter referred to as States) with improving 

the administration of federal elections and to provide funds to States to help implement these 

improvements. The Commission administers grants to States authorized by HAVA under Title I, 

as follows: 

• Title I, Section 101 payments are for activities such as complying with Title III of HAVA 

for uniform and nondiscriminatory election technology and administration requirements; 

improving the administration of elections for Federal office; educating voters; training 

election officials and poll workers; developing a state plan for requirements payments; 

improving, acquiring, leasing, modifying, or replacing voting systems and methods for 

casting and counting votes; improving the accessibility and quantity of polling places; and 

establishing toll-free telephone hotlines that voters may use. 

The 2018 HAVA Election Security Grant also requires that states must: 

• Provide matching funds equal to 5 percent of the total federal funds within two years of the 

award to be spent for activities for which Election Security Grants are made. 

• Maintain all federal funds and state cash matching funds in the state election fund, as 

described in Section 104 (d) of HAVA, along with interest earned on the award’s funds. 

States may also track eligible funds/activities from their state and local general operating 

budgets to meet the match obligations. State and local funds used for match must be 

different from funds used to meet Maintenance of Effort or state match associated with 

HAVA Requirement Payments. 

The Awardee – The West Virginia Secretary of State 

The HAVA funds were awarded to the West Virginia Secretary of State. The West Virginia 

Secretary of State Elections Division serves as the Chief Elections Officer of West Virginia and 

oversees the election process throughout the state along with the recording of official campaign 

financial records and candidate filings. The Secretary of State is a member of the State Election 

Commission, the Board of Public Works, and the State Armory Board. 

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Help America Vote Act State of West Virginia State Plan 

The State of West Virginia’s HAVA budget letter was prepared by the Secretary of State. The 

main objectives of the project funded by HAVA, as set forth in the budget letter, were to use the 

newly appropriated HAVA funds exclusively as grants or loans directly to local election officials 

to boost their purchasing power for elections systems and security. The funds were to be added to 

the current County Grant and Loan Fund. 

County Grant and Loan Fund monies may be used by the counties for election equipment (up to 

50% grant with a 50% local match), physical security (up to 85% grant with a 15% local match), 

cybersecurity (up to 85% grant with a 15% local match), and e-pollbooks (up to 85% grant with a 

15% local match). 

All County Grant and Loan Fund monies were spent by local jurisdictions. $3,275,178 of the funds 

were spent on voting equipment, $125,845 was spent on cyber security, $129,512 was spent on epollbooks and $74,926 was spent on physical security. 

AUDIT OBJECTIVES 

The objectives of our audit were to determine whether the Office: 

1. Used funds for authorized purposes in accordance with Section 101 of HAVA and other 

applicable requirements; 

2. Properly accounted for and controlled property purchased with HAVA payments; and 

3. Used the funds in a manner consistent with the budget plan provided to EAC. 

In addition to accounting for Grant payments, the Grant requires states to maintain records that are 

consistent with sound accounting principles that fully disclose the amount and disposition of the 

payments, that identify the project costs financed with the payments and other sources, and that 

will facilitate an effective audit. The Commission requires states receiving Grant funds to comply 

with certain financial management requirements, specifically: 

• Expend payments in accordance with Federal cost principles established by the Office of 

Management and Budget (OMB) – (2 CFR 200). 

• Submit detailed annual financial reports on the use of Title I payments. 

• Maintain documents and records subject to audit to determine whether payments were used 

in compliance with HAVA. 

SCOPE AND METHODOLOGY 

We audited the Grant funds received and disbursed by the Office, from June 29, 2018 through 

September 30, 2019. These funds are related to the appropriation of $380 million under the 

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Consolidated Appropriations Act (CAA), 2018 (P.L. 115-151). The scope of activity audited is 

shown in the following table: 

Election 

Description Security Funds 

Funds Received from EAC $ 3,611,943 

State Matching Funds 180,597 

Program Income 32,613 

Total Funds $ 3,825,153 

Less Disbursements (3,786,058) 

Fund Balance $ 39,095 

The Office’s expenditures detailed by budget and program category are included as Appendix C. 

In planning and performing our audit, we identified the following internal control components and 

underlying internal control principles as significant to the audit objective: 

Objective Component Principle 

1 Control Activities Selects and develops control activities 

Selects and develops general controls over technology 

Deploys through policies and procedures 

Information and Communication Uses Relevant Information 

Communicates Internally 

2 Control Activities Selects and develops control activities 

Selects and develops general controls over technology 

Deploys through policies and procedures 

Information and Communication Communicates Externally 

3 Control Activities Selects and develops control activities 

Selects and develops general controls over technology 

Deploys through policies and procedures 

We assessed the design, implementation, and operating effectiveness of these internal controls and 

identified deficiencies that we believe could affect the Office’s ability to use funds for authorized 

purposes, and properly account for and control property. The internal control deficiencies we found 

are discussed in the Audit Results section of this report. 

Additionally, for the components and principles which we determined to be significant, we 

assessed the internal controls and compliance with laws and regulations necessary to satisfy the 

audit objective. 

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However, because our review was limited to these internal control components and underlying 

principles, it may not have disclosed all internal control deficiencies that may have existed at the 

time of this audit. 

AUDIT RESULTS 

We conducted this performance audit in accordance with Generally Accepted Government 

Auditing Standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on the audit objectives. 

Based on the audit procedures performed, except for the matters discussed below, we concluded 

that the Office accounted for and expended the HAVA funds in accordance with the requirements 

mentioned above, properly accounted for and controlled property purchased, and used the funds 

in a manner consistent with the budget plan for the period from June 29, 2018 through September 

30, 2019. The exceptions to applicable compliance requirements are described below. 

Finding No. 1 – Financial Reporting of Federal Share of Expenditures and Program Income 

The Office submitted financial reports for Election Security funds that did not agree to the 

underlying accounting records. 

The Office's latest Federal Financial Report (FFR) submission of the Election Security grant funds 

was for the period ending September 30, 2019. The amount of federal expenditures and federal 

program income did not agree to the accounting records. The discrepancies noted are as follows: 

FFR Accounting 

Reported Records Variance 

Federal Share of Expenditures $ 3,587,122 $ 3,605,461 $ 18,339 

Federal Program Income 40,496 32,613 (7,883) 

The terms and conditions of the Election Security grant awards require the submission of an 

accurate and complete Federal Form 425 (Federal Financial Report) which reflect the uses of 

award funds and the interest and program income generated from those funds. HAVA Title IX, 

Section 902. AUDITS AND REPAYMENT OF FUNDS, Part (a) – Recordkeeping Requirement 

states, “Each recipient of a grant or other payment made under this Act shall keep such records 

with respect to the payment as are consistent with sound accounting principles, including records 

which fully disclose the amount and disposition by such recipient of funds, the total cost of the 

project or undertaking for which such funds are used, and the amount of that portion of the cost of 

the project or undertaking supplied by other sources, and such other records as will facilitate an 

effective audit.” 

The errors were caused by the Office miscalculating the remaining balance of the prior HAVA 

funds and the ending balance of the Election Fund at September 30, 2019. 

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Proper reporting of all grant activity ensures that the funds are tracked and spent in accordance 

with federal regulations. 

Recommendation 

We recommend that the EAC review and resolve the following recommendations that the Office: 

1. Perform a reconciliation of the grant activity for the Election Security funds and ensure 

that all expenditures and program income earned are fully disclosed. 

2. Prepare and submit a revised financial report to the EAC for Election Security funds and 

the prior HAVA fund activities as of September 30, 2019. 

Secretary of State Response: 

In response to the errors in miscalculation on the 2019 Election Security Grants FFR, the Secretary 

of State's Office has performed a reconciliation of the grant activity to ensure all expenditures and 

program income earned are fully disclosed. A revised financial report is attached with this letter. 

Auditor’s Response: 

We have reviewed the revised Federal Financial Report provided by the Office and noted that the 

amounts reported are in agreement with the underlying accounting records. 

Finding No. 2 – Subrecipient Monitoring 

The Office’s monitoring of subrecipients did not ensure that property records were maintained in 

compliance with 2 CFR 200. Five out of 27 subrecipients were randomly selected for physical 

observation of equipment. The five subrecipients were the counties of Boone, Cabell, Kanawha, 

Lincoln and Logan. These five counties represented $1,380,171 of the reported voting equipment 

purchases of $3,275,178. The property records for four of the counties (Boone, Cabell, Lincoln 

and Logan) did not include all information required by 2 CFR 200. Total voting equipment 

purchased by these four counties was $1,356,702. Voting equipment purchased with $293,455 of 

election security funds was selected from the five counties for observation and was determined to 

exist. 

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards (Uniform Guidance) at 2 CFR 200.331 (d) states that all pass-through entities must: 

“Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for 

authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions 

of the subaward; and that subaward performance goals are achieved.” Further, the subaward 

agreement executed with each county stated, “for equipment purchases over $5,000, 2 CFR 

200.310 (regarding insurance generally) and particularly 2 CFR 200.[3]13 provide requirements 

for the title, usage, management and maintenance of that equipment, including a physical 

inventory.” 

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The Office did not perform activity monitoring sufficient to ensure that subrecipients were 

maintaining property records in compliance with Federal statutes and the terms and conditions of 

the subaward. Due to this, Boone, Cabell, Lincoln and Logan counties’ property records were 

limited to a description of the property, the serial number, and the location. 

Proper monitoring of property purchased by subrecipients with federal funds ensures that 

equipment is being used and disposed of in accordance with federal regulations. 

Recommendation 

3. We recommend that the EAC address and resolve the following recommendation that the 

Office implement procedures to ensure that all subrecipients are properly monitored and 

all property purchased with federal funds is placed on a compliant property record. 

Secretary of State Response: 

In response to proper monitoring of property purchased by subrecipients, in January 2021 the 

Secretary of State will retrain county clerks on entering HAVA inventory in the Statewide Voter 

Registration System to ensure that it is in a centralized location. The county clerks will receive a 

follow-up survey to confirm that all of their HAVA inventory has been entered correctly into the 

system. Finally, they will be asked to confirm that the list with all required information will be the 

list that they present in any future audits. 

Auditor’s Response: 

The proposed corrective actions, if implemented, would be sufficient to correct the finding. 

We provided a draft of our report to the appropriate individuals of the Office of the West Virginia 

Secretary of State. We considered any comments received prior to finalizing this report. 

The Office responded on January 4, 2021 and generally agreed with the report’s findings and 

recommendations. The EAC responded on January 6, 2021 and stated that they are reviewing the 

Office’s planned actions. The Office’s complete response is included as Appendix A-1 and the 

EAC’s complete response as Appendix A-2. 

McBride, Lock & Associates, LLC performed the related audit procedures between December 6, 

2019 and January 4, 2021. 

(Original Signed by McBride, Lock & Associates, LLC) 

McBride, Lock & Associates, LLC 

Kansas City, Missouri 

January 4, 2021 

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Appendix A-1 

Response of the West Virginia 

Secretary of State to the Draft Report 
Office of the Secretary of State Mac Warner Telephone: (304) 558-6000 

State Capitol Secretary of State Toll Free: 1-866-SOS-VOTE 

Charleston, West Virginia 25305 State of West Virginia Fax: (304) 558-0900 

www.wvsos.gov 

Via Electronic Transmission 

January 4, 2021 

Patricia L. Layfield, CPA, CIA, CISA 

Inspector General 

U.S. Election Assistance Commission 

633 3rd Street, NW, Suite 200 

Washington, DC 20001 

Dear Ms. Layfield, 

In response to the errors in miscalculation on the 2019 Election Security Grants FFR, the Secretary of 

State's Office has performed a reconciliation of the grant activity to ensure all expenditures and 

program income earned are fully disclosed. A revised financial report is attached with this letter. 

In response to proper monitoring of property purchased by subrecipients, in January 2021 the Secretary 

of State will retrain county clerks on entering HAVA inventory in the Statewide Voter Registration 

System to ensure that it is in a centralized location. The county clerks will receive a follow-up survey to 

confirm that all of their HAVA inventory has been entered correctly into the system. Finally, they will be 

asked to confirm that the list with all required information will be the list that they present in any future 

audits. 

Sincerely, 

Brittany Westfall, Director of Elections 
Appendix A-2 

Response of the 

U.S. Election Assistance Commission 

to the Draft Report 
 

U.S. ELECTION ASSISTANCE COMMISSION 

633 3rd Street, NW Suite 200 

Washington, DC 20001 

TO: Patricia Layfield 

Inspector General 

FROM: Mona Harrington 

Executive Director 

DATE: January 6, 2021 

RE: Response to the Draft Performance Audit Report, Administration of 

Payments Received under the Help America Vote Act by the West Virginia 

Secretary of State 

Thank you for the opportunity to respond to the draft performance audit report of EAC’s 

grant funds to West Virginia. 

We appreciate the auditor’s findings and recommendations and are reviewing the West 

Virginia Secretary of State’s office planned actions. The state submitted a revised Federal 

financial Report (FFR) to correct the miscalculation errors and plans to retrain county 

staff on entering inventory data into their statewide system. With these actions, the 

findings in the draft report will be addressed and EAC can provide its management 

decision to the OIG soon after the audit report is issued as final. 
 

 

 

Appendix B 

AUDIT SCOPE AND METHODOLOGY 

Our audit methodology included: 

• Assessing audit risk and significance within the context of the audit objectives. 

• Obtaining an understanding of internal control that is significant to the administration of 

the HAVA funds and of relevant information systems controls as applicable. 

• Identifying sources of evidence and the amount and type of evidence required. 

• Determining whether other auditors have conducted, or are conducting, audits of the 

program that could be relevant to the audit objectives. 

As part of our audit, we gained an overall understanding of the internal control environment at the 

Office. Based on this understanding, we identified certain internal controls that we considered to 

be significant (or key controls) to achieving each objective. All components of internal control are 

relevant, but not all may be significant. Significance is defined as the relative importance of a 

matter within the context in which it is being considered, and is a matter of professional judgment. 

We made the following determination as to the significance of the underlying internal control 

principles: 

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Objective 

1 2 3 

Control Environment 

1. Demonstrates Commitment to integrity and ethical values No No No 

2. Exercises oversight responsibility No No No 

3. Establishes structure, authority, and responsibility No No No 

4. Demonstrates commitment to competence No No No 

5. Enforces accountability. No No No 

Risk Assessment 

6. Specifies suitable objectives No No No 

7. Identifies and analyzes risk No No No 

8. Assesses fraud risk No No No 

9. Identifies and analyzes significant change No No No 

Control Activities 

10. Selects and develops control activities Yes Yes Yes 

11. Selects and develops general controls over technology Yes Yes Yes 

12. Deploys through policies and procedures Yes Yes Yes 

Information and Communication 

13. Uses relevant information Yes No No 

14. Communicates internally Yes No No 

15. Communicates externally No Yes No 

Monitoring 

16. Conducts ongoing and/or separate evaluations No No No 

17. Evaluates and communicates deficiencies No No No 

The significance was determined as follows: 

Objective 1: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

proper use of funds and compliance with award requirements. 

The Information and Communication principles of Use Relevant Information and Communicate 

Internally were deemed to be significant to our determination of the awardee’s compliance with 

the FFR reporting portion of this objective. These principles address the quality of the information 

and the internal communication processes used to compile the data necessary to meet the state’s 

reporting objectives. 
 

 

 

 

 

 

 

 

Objective 2: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

proper accounting and control over equipment purchased with HAVA funds. 

The Information and Communication principle of Communicate Externally was deemed to be 

significant to our determination of the awardee’s compliance with the objective because the state 

communicated with and relied on information from the counties as to where the equipment is 

located as part of the control system for accounting and controlling equipment purchased with 

HAVA funds. 

Objective 3: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

use of funds in a manner consistent with the plans provided to EAC. 

To implement our audit methodology, below are some of the audit procedures we performed. 

• Interviewed appropriate Office employees about the organization and operations of the 

HAVA program. 

• Reviewed prior single audit reports and other reviews related to the State’s financial 

management systems and the HAVA program for the period under review. 

• Reviewed policies, procedures and regulations for the Office management and accounting 

systems as they relate to the administration of the HAVA program. 

• Tested major subaward purchases and the supporting documentation. 

• Tested randomly sampled subaward payments made with HAVA funds. 

• Evaluated compliance with the requirements for accumulating financial information 

reported to the Commission on the financial status reports and progress reports, accounting 

for property, purchasing HAVA related goods and services, and using funds in a manner 

consistent with the budget plan provided to EAC. 

• Verified the establishment and maintenance of an election fund. 

• Observed the physical security/safeguards of selected equipment purchased with HAVA 

funds and ensure compliance with federal regulation. 

• Verified whether the matching requirement was met and, if so, that matching expenditures 

met the prescribed criteria and allowability requirements of HAVA. 

• Verified program income was properly accounted for and not remitted to the State’s 

general fund. 
 

 

 

 

 

 

 

 

 

 

Appendix C 

EXPENDITURES BY BUDGET CATEGORY AND PROGRAM CATEGORY 

JUNE 29, 2018 TO SEPTEMBER 30, 2019 

Program Categories 

Other - HAVA 

Voter Grant and Loan 

Voting Election Registration Cyber Board 

Budget Categories Equipment Auditing Systems Security Communications Distribution Total 

Personnel (Including Fringe) $ - $ - $ - $ - $ - $ - $ -

Equipment - - - - - - -

Subgrants - - - - - 3,605,461 3,605,461 

Training - - - - - - -

All Other Costs - - - - - - -

Total Direct Costs $ - $ - $ - $ - $ - $ 3,605,461 $ 3,605,461 

Indirect Costs (if applied) - - - - - - -

Total Federal Expenditures $ - $ - $ - $ - $ - $ 3,605,461 $ 3,605,461 

Non-Federal Match - - 162,000 - - 18,597 180,597 

Total Program Expenditures $ - $ - $ 162,000 $ - $ - $ 3,624,058 $ 3,786,058 

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Subgrant Spending By Program Categories 

Voter Other - 

Voting Election Registration Cyber Other - E- Physical 

County Equipment Auditing Systems Security Communications Pollbooks Security Total 

BARBOUR $ 110,000 $ - $ - $ 7,578 $ - $ - $ - $ 117,578 

BOONE 213,021 - - - - - - 213,021 

BRAXTON - - - 5,368 - - - 5,368 

CABELL 667,724 - - - - - - 667,724 

CLAY - - - 7,544 - - - 7,544 

DODDRIDGE 112,196 - - 18,819 - - - 131,015 

FAYETTE 38,512 - - - - - 14,037 52,549 

GRANT 106,473 - - 6,834 - - - 113,307 

GREENBRIER - - - 17,918 - 39,994 - 57,912 

HAMPSHIRE 158,273 - - 36,869 - - - 195,142 

HANCOCK 229,137 - - 4,282 - - 1,554 234,973 

HARDY - - - 4,608 - - - 4,608 

HARRISON 59,386 - - - - - - 59,386 

JACKSON 302,911 - - - - - 13,815 316,726 

JEFFERSON 1,312 - - 2,361 - 42,661 374 46,708 

KANAWHA 23,469 - - - - - 16,057 39,526 

LINCOLN 207,056 - - - - - 2,460 209,516 

LOGAN 268,901 - - - - - - 268,901 

MARION - - - - - 6,120 - 6,120 

MERCER - - - - - - 22,640 22,640 

MINERAL - - - 7,578 - - 3,989 11,567 

MINGO 281,473 - - - - - - 281,473 

MONROE 146,291 - - - - - - 146,291 

NICHOLAS 130,000 - - - - - - 130,000 

OHIO - - - - - 40,737 - 40,737 

PENDLETON 109,294 - - 6,086 - - - 115,380 

POCAHONTAS 109,749 - - - - - - 109,749 

Total Direct Costs $ 3,275,178 $ - $ - $ 125,845 $ - $ 129,512 $ 74,926 $ 3,605,461 

Indirect Costs (if applied) - - - - - - - -

Total Federal Expenditures $ 3,275,178 $ - $ - $ 125,845 $ - $ 129,512 $ 74,926 $ 3,605,461 

14 
Appendix C 

MONETARY IMPACT AS OF SEPTEMBER 30, 2019 

Additional 

Questioned Unsupported Funds for 

Description Costs Costs Program 

None $ - $ - $ -

Total $ - $ - $ -

15 
 

 

 

 

 

 

 

 

 

 

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