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REPORT ON STATEWIDE COMPLIANCEFOR THE QUARTER ENDEDSEPTEMBER 30, 2019OFFICE OF THE COMPTROLLERDEPARTMENT OF ACCOUNTS
Prepared and Published byDepartment of AccountsCommonwealth of VirginiaP. O. Box 1971Richmond, VA 23218-1971Text and graphics were produced usingMicrosoft Word for Windows in Arialand Times New Roman fonts.
TABLE OF CONTENTSREPORT ON STATEWIDE COMPLIANCEQuarter Ended September 30, 2019PageSTATEMENT OF PURPOSE . 2COMPLIANCE .Auditor of Public Accounts Reports - Executive Branch and Independent Agencies .Audit Reports.Audit Findings .Risk Alerts .Special Reports .Other Audit Reports.Internal Control Questionnaires .Summary of Prior Audit Findings .Status of Prior Audit Findings .Annual Summary of APA Audit Findings.Compliance Monitoring .ARMICS Compliance.Certification of Agency Reconciliation to Cardinal Reports .E-Commerce .Travel Check Charges .Payroll Controls .CIPPS/PMIS Payroll Audit .Payroll Certification .Health Care Reconciliations .9/30/19 Quarterly ent of Accounts
STATEMENT OF PURPOSEThe Code of Virginia requires that the Department of Accounts (DOA) monitor and account forall transactions involving public funds. In order to carry out this mandate, the Department uses avariety of measures, including automated controls, statistical analyses, pre-audits and post-audits,staff studies and reviews of reports issued by the Auditor of Public Accounts. When taken as awhole, these measures provide an important source of information on the degree of agencycompliance with Commonwealth accounting and financial management policies, internal controls,procedures, regulations, and best practices.The Comptroller’s Report on Statewide Compliance (the Quarterly Report) is a summary ofmeasures used by DOA to monitor transactions involving public funds and report findings to theGovernor, his Cabinet, and other senior State officials. The Quarterly Report uses exceptionreporting to highlight key findings.This Quarterly Report includes information for the quarter ended September 30, 2019, andcomparative FY 2019 data.David A. Von Moll, CPA, CGFMComptroller9/30/19 Quarterly Report2Department of Accounts
COMPLIANCEAuditor of Public Accounts Reports - Executive Branch and Independent AgenciesAgency audit reports issued by the Auditor of Public Accounts (APA) may contain findingsbecause of noncompliance with state laws and regulations. Agencies may also have internalcontrol findings considered to be control deficiencies. Control deficiencies occur when the designor operation of internal control does not allow management or employees to prevent or detecterrors that, in the Auditor’s judgment, could adversely affect the agency’s ability to record,process, summarize, and report financial data consistent with the assertions of management.Each agency must provide a written response that includes a Corrective Action Workplan (CAW) tothe Department of Planning and Budget, the Department of Accounts, and the agency’s CabinetSecretary when its audit report contains one or more audit findings. Workplans must be submittedwithin 30 days of receiving the audit report. Commonwealth Accounting Policies and Procedures(CAPP) manual, Topic No. 10205, Agency Response to APA Audit, contains instructions and guidanceon preparing the workplan.The APA also reports additional recommendations that can include risk alerts, efficiency issues,or any other improvements that can be made within agency operations. Risk alerts address issuesthat are beyond the capacity of agency management to implement effective corrective actions.Efficiency issues provide management with recommendations to enhance agency practices,processes or procedures. Additional recommendations are provided following the Audit Findingssection.The APA also issued several Special and Other Reports during the quarter. These reports are listedfollowing the Additional Recommendations section. The full text of these reports is available atwww.apa.virginia.gov.Audit Reports – Quarter Ended September 30, 2019The APA issued 9 reports covering 29 State Agencies for the Executive Branch and 1 report forthe Independent Agencies. The last column indicates whether the CAW has been received as ofthe date of this publication for each agency with audit findings. Note that in some cases, the CAWmay not have been received because it is not yet due.AdministrationNoneAgriculture and ForestryNoneCommerce and TradeNoneEducationLongwood UniversityThe Science Museum of VirginiaVirginia Community College System – Central Office(1)9/30/19 Quarterly ceived512402914YESYESYESDepartment of Accounts
Virginia Community College System – Shared ServiceCenter(1)Central Virginia Community College(1)Dabney S. Lancaster Community College(1)Germanna Community College(1)J. Sargeant Reynolds Community College(1)Lord Fairfax Community College(1)Mountain Empire Community College(1)New River Community College(1)Northern Virginia Community College(1)Patrick Henry Community College(1)Paul D. Camp Community College(1)Piedmont Virginia Community College(1)Rappahannock Community College(1)Tidewater Community College(1)Virginia Western Community College(1)Virginia Museum of Fine ArtsVirginia State UniversityExecutive OfficesNoneFinanceBoard of AccountancyHealth and Human ResourcesDisability Services Agencies(2)Department of Aging and Rehabilitative ServicesDepartment for the Blind and Vision ImpairedDepartment for the Deaf and Hard-of-HearingVirginia Board for People with DisabilitiesIndependent AgenciesState Corporation CommissionNatural ResourcesDepartment of Game and Inland FisheriesPublic Safety and Homeland ns and Defense AffairsDepartment of Veterans YESYES123YES325NO404YESThe APA issued one report titled “Virginia Community College System Report on Audit for the yearended June 30, 2018.”Disability Services Agencies – Audit of Select Cycles for the year ended June 30, 2018Audit of Patient Care Revenue9/30/19 Quarterly Report4Department of Accounts
Audit Findings - Quarter Ended September 30, 2019The following agencies had one or more findings contained in their audit report.EducationLongwood University1. Improve Financial Reporting Processes. This is a Material Weakness.2. Strengthen Internal Controls over Capital Assets. This is a Material Weakness and a PartialRepeat Finding.3. Improve Database Security and Information System Access Controls. This is a MaterialWeakness and a Repeat Finding.4. Continue to Improve Oversight of Third-Party Service Providers. This is a Repeat Finding.5. Continue to Improve Continuity of Operations Planning. This is a Repeat Finding.6. Improve Information Security Policies and Procedures7. Improve Firewall Security8. Improve Reporting to the National Student Loan Data System9. Properly Process Title IV Refund CalculationsThe Science Museum of Virginia1. Improve Processes and Controls over Employment EligibilityVirginia Community College System – Central Office1.2.3.4.Encourage Community Colleges and the Shared Services Center to Control System AccessContinue Improving Vulnerability Mitigation Efforts. This is a Partial Repeat Finding.Improve Web Application SecurityContinue to Complete a Risk Assessment for Each Sensitive System. This is a Partial RepeatFinding.Virginia Community College System – Shared Services Center1.2.3.4.5.Ensure Proper Processing and Approval of VouchersPerform a Proper Evaluation and Analysis of System Access LevelsEnsure Contracts Are Valid and CurrentObtain Information Needed to Enforce Revenue Contract DeliverablesEnsure Vendors Are Aware of Special Instructions and Automated Processes Work as IntendedCentral Virginia Community College1.2.3.4.5.6.7.Reconcile Financial Aid Activity to Federal Systems. This is a Repeat Finding.Improve Reporting to National Student Loan Data System. This is a Repeat Finding.Properly Process Title IV Refund CalculationsReturn Unclaimed Aid to Department of EducationImprove Cash Management ProceduresPerform Monthly Bank ReconciliationsImprove Reporting to the Common Origination and Disbursement SystemDabney S. Lancaster Community College1. Improve Reporting to National Student Loan Data System9/30/19 Quarterly Report5Department of Accounts
Germanna Community College1. Develop and Document Policies and Procedures for Operationalizing Payroll and HumanResource Functions2. Remove System Access No Longer Necessary to Perform Job Duties3. Improve Payroll Document Retention4. Develop and Implement Policies and Procedures for Employee Terminations5. Document Justification for Prepaying ExpensesJ. Sargeant Reynolds Community College1. Improve Direct Loan Reconciliations2. Resolve Federal Department of Education FindingsLord Fairfax Community College1. Ensure Staff Transmits Sensitive Information Securely2. Ensure Staff Responsible for Fixed Asset Inventory Receive Training3. Ensure Adequate Staffing to Provide for Proper Separation of Duties Over the Cash CollectionProcess4. Ensure Proper Capitalization of Fixed Assets5. Improve Effectiveness of System Access Controls6. Review Leave Liability Report for Accuracy7. Improve Documentation for Small Purchase Charge Cards8. Identify and Report Leases to Support the System’s Financial Statements9. Develop Policies and Procedures for Adjunct Employees without an Active Contract10. Maintain Proper Documentation for System Access Termination11. Maintain Documentation for Federal Aid Program Reconciliations12. Identify and Report Prepaid Expenses13. Assign Responsibility for Proper Coding14. Develop Policies and Procedures to Address Exceptions between the Commonwealth’s Payrolland Human Resource SystemsNew River Community College1.2.3.4.5.Improve Critical System Access MonitoringImprove Fixed Asset Inventory and TrackingEnsure Contracts Are Properly MonitoredConfirm Virginia Retirement System Snapshot TimelyProperly Report AccrualsNorthern Virginia Community College1. Follow Commonwealth Requirements for the Stewardship of Fixed Assets. This is a RepeatFinding.2. Improve Effectiveness of System Access Controls3. Ensure Proper Processing of Vouchers4. Ensure All Contracts Are Valid and Current5. Implement Effective Exit Procedures for Adjunct Faculty and Wage Employees. This is aRepeat Finding.6. Complete Employment Eligibility Verification within the Required Timeframe7. Improve Reporting to National Student Loan Data System9/30/19 Quarterly Report6Department of Accounts
Patrick Henry Community College1.2.3.4.5.Improve the Management of Critical System AccessImprove Fixed Asset Inventory Procedures and Tracking of Fixed AssetsEnsure Revenue Generating Contracts Are Current and Properly MonitoredEnsure Human Resources Department Corrects Inaccurate Employee Leave BalancesComply with Employment Eligibility RequirementsPaul D. Camp Community College1. Improve Reporting to National Student Loan Data System. This is a Repeat Finding.Piedmont Virginia Community College1. Improve Controls over Fixed Asset Inventory2. Remove System Access When Employees No Longer Need Access3. Properly Monitor Grant Programs to Ensure Proper Accounting and Compliance for AccountsReceivable4. Properly Consider if the Costs Associated with Putting an Asset into Service Should beCapitalized5. Ensure Payroll Reconciliation is Performed as Required6. Perform and Document Retirement Benefit System Reconciliations7. Confirm Retirement Contributions within the Required Timeframe8. Properly Accrue Prepaid Expenses9. Return Unearned Title IV Funds Timely10. Perform Accurate Return of Title IV Calculations11. Reconcile Federal Aid Programs Timely12. Improve Reporting to National Student Loan Data SystemRappahannock Community College1.2.3.4.Ensure Revenue is Recorded Timely and AccuratelyUpdate Policies and Procedures for Cash Management RequirementsAssign Contracts Administrator Responsibilities in WritingProperly Document Federal Aid ReconciliationsTidewater Community College1.2.3.4.5.Perform Effective Reviews of System AccessProperly Monitor Revenue Contract DeliverablesStrengthen Interdepartmental Communications Related to Terminated EmployeesEnsure Prepaid Expenses and Other Payments Comply with Commonwealth RequirementsImprove Reporting to National Student Loan Data SystemVirginia Western Community College1. Improve Notification Process for Federal Direct Loan Awards to Students2. Reconcile Federal Aid Programs Timely3. Resolve Federal Department of Education FindingsVirginia Museum of Fine Arts1. Properly Record Assets in the Commonwealth’s Capital Asset System2. Implement Policies and Procedures over Construction in Progress3. Reconcile Capital Assets Monthly9/30/19 Quarterly Report7Department of Accounts
Virginia State University1. Improve Virtual Private Network Security. This is a Repeat Finding.2. Improve User Access Controls. This is a Partial Repeat Finding.3. Improve Documentation of Emergency and Sole Source Procurement. This is a Repeat Finding.4. Develop Procedures for Proper Accrual of Accounts Payable5. Strengthen Internal Controls over Capital Assets6. Enhance Special Pay Monitoring Controls7. Improve Processes for Employment Eligibility8. Improve Processes over Payroll and Human Resource Reconciliations9. Establish a Process for Periodically Reviewing Stagnate Grants and Contributions10. Improve IT Asset Surplus Process11. Improve Reporting to National Student Loan Data System12. Improve Reporting to the Common Origination and Disbursement SystemHealth and Human ResourcesDisability Services AgenciesDepartment for Aging and Rehabilitative Services1. Update Disability Services Agencies Memorandum of Understanding2. Improve Internal Controls over Financial System Reconciliations3. Improve Internal Controls over Client Gift and Fuel Card Purchases. This is a Partial RepeatFinding.4. Improve Purchase Card Reconciliations and Document Retention. This is a Partial RepeatFinding.5. Improve Documentation over Traveler’s Reimbursement of Purchase Cards. This is a PartialRepeat Finding.Department for the Blind and Vision Impaired1. Update Disability Services Agencies Memorandum of Understanding2. Improve Internal Controls over Financial System Reconciliations3. Improve Purchase Card Reconciliations and Document Retention. This is a Partial RepeatFinding.4. Improve Controls over System Access5. Develop and Implement Information Security Policies and Procedures6. Upgrade Manufacturing System7. Improve Information Security for Point of Sale System8. Improve Oversight over Third-Party Providers9. Improve Information Technology GovernanceDepartment for the Deaf and Hard-of-Hearing1. Update Disability Services Agencies Memorandum of Understanding2. Improve Purchase Card Reconciliations and Document Retention. This is a Partial RepeatFinding.9/30/19 Quarterly Report8Department of Accounts
Virginia Board for People with Disabilities1. Update Disability Services Agencies Memorandum of Understanding2. Improve Purchase Card Reconciliations and Document Retention. This is a Partial RepeatFinding.Independent AgenciesState Corporation Commission1. Continue Improving Information Security Program. This is a Repeat Finding.2. Continue Improving Logical Access Controls. This is a Repeat Finding.3. Develop and Implement Alternative Controls for Manual PaymentsNatural ResourcesDepartment of Game and Inland Fisheries1.2.3.4.5.Perform Annual Access Review of the Commonwealth’s Attendance and Leave SystemImprove Employment Eligibility ProcessImprove Completion and Performance of Physical Inventories. This is a Repeat Finding.Improve Policies Surrounding Reconciliation of Capital AssetsImprove the Tracking and Reporting of Construction in Progress. This is a Repeat Finding.Veterans and Defense AffairsDepartment of Veterans Services1.2.3.4.Review and Document Service Organization Control ReportsEnsure Annual System Access Reviews are PerformedStrengthen Procedures over Terminated Employee System AccessGrant System Access on the Principle of Least Privilege9/30/19 Quarterly Report9Department of Accounts
Risk Alerts – Quarter Ended September 30, 2019No “Risk Alerts” were issued.Special Reports – Quarter Ended September 30, 2019The APA issued the following “Special Reports” that did not contain management findings:Progress Report on Implementation of JLARC Recommendations as of June 2019Report to the Joint Legislative Audit and Review Commission for the quarter April 1, 2019through June 30, 2019Virginia Retirement System GASB 68 Schedules: Political Subdivision Retirement Plans for the fiscal year ended June 30, 2018 State Employee Retirement Plan for the fiscal year ended June 30, 2018 Teacher Retirement Plan for the fiscal year ended June 30, 2018Virginia Retirement System GASB 75 Schedules: Commonwealth of Virginia State Health Plans Program for Pre-Medicare Retireesfor the fiscal year ended June 30, 2018 Department of Human Resource Management – Commonwealth of Virginia StateHealth Plans Program for Pre-Medicare Retirees for the year ended June 30, 2018 Disability Insurance Program for the fiscal year ended June 30, 2018 Group Life Insurance Plan for the fiscal year ended June 30, 2018 Political Subdivision Health Insurance Credit Plans for the fiscal year ended June30, 2018 State Health Insurance Credit Plan for the year ended June 30, 2018 Teacher Health Insurance Credit Plan for the fiscal year ended June 30, 2018 Virginia Retirement System – Line of Duty Act Program for the year ended June30, 2018Virginia Retirement System Management’s Assertions Related to Census Data for OPEBPlans for the year ended June 30, 2017Virginia Retirement System Management’s Assertions Related to Census Data for the yearended June 30, 2017The APA issued the following “Special Reports” that contained management recommendations:Information Technology Project Progress Report as of March 31, 2019Local Government Fiscal Distress Monitoring as of June 2019Report on Compliance – NCAA Subsidy Percentage Requirements for the year ended June30, 20189/30/19 Quarterly Report10Department of Accounts
Virginia District Court System for the year ended June 30, 2018Other Audit Reports – Quarter Ended September 30, 2019The APA issued the following “Other Reports” that did not contain managementrecommendations:Virginia Lottery – Reports on Applying Agreed-Upon Procedures for the period April 2018through March 2019:·····Cash4LifeMega MillionsMegaplierPower PlayPowerballThe APA issued the following “Other Reports” that contained management recommendations:Innovation and Entrepreneurship Investment Authority, including its Blended ComponentUnit, Center for Innovative Technology and Subsidiaries for the year ended June 30, 2018Potomac River Fisheries Commission for the year ended June 30, 2019Virginia State Bar for the year ended June 30, 2018Internal Control Questionnaire Reviews for the Quarter June 30, 2019The APA issued the following “Internal Control Questionnaire Reviews” that containedmanagement recommendations:Department of Conservation and Recreation Internal Control Questionnaire ReviewResults as of May 2019Department of Housing and Community Development Internal Control QuestionnaireReview Results as of June 2019Department of Labor and Industry Internal Control Questionnaire Review Results as ofMay 2019Marine Resources Commission Internal Control Questionnaire Review Results as of May2019Payroll Service Bureau Internal Control Questionnaire Review Results as of May 2019Southern Virginia Higher Education Center Internal Control Questionnaire Review Resultsas of May 20199/30/19 Quarterly Report11Department of Accounts
Southwest Virginia Higher Education Center Internal Control Questionnaire ReviewResults as of June 2019Virginia Health Workforce Development Authority Internal Control Questionnaire ReviewResults as of May 2019The APA issued the following “Internal Control Questionnaire Review” that did not containmanagement recommendations:Department of Small Business and Supplier Diversity Internal Control QuestionnaireReview Results as of June 20199/30/19 Quarterly Report12Department of Accounts
Auditor of Public Accounts Reports - Executive Branch AgenciesSummary of Prior Audit FindingsThe policy governing the Agency Response to APA Audits requires follow-up reports on agencyworkplans every quarter end until control findings are certified by the agency head as corrected.The status of corrective action information reported by agencies under this policy is summarizedin this report.It is important to note that the finding status reported is self-reported by the agencies and will besubject to subsequent review and audit. Corrective action is considered to be delayed when it hasnot been completed by the original targeted date. Additional detail for the status of each finding isprovided in the subsequent table.IN PROGRESSOnScheduleDelayedAdministrationDepartment of General ServicesDepartment of Human Resource ManagementCommerce and TradeVirginia Employment CommissionEducationDepartment of EducationChristopher Newport UniversityGeorge Mason UniversityJames Madison UniversityLongwood UniversityNorfolk State UniversityOld Dominion UniversityRadford UniversityRichard Bland CollegeSouthern Virginia Higher Education CenterThe College of William and Mary in VirginiaUniversity of Mary WashingtonUniversity of Virginia Medical CenterVirginia Community College System – CentralOfficeNorthern Virginia Community CollegePaul D. Camp Community CollegeThomas Nelson Community CollegeVirginia Military InstituteVirginia School for the Deaf and BlindVirginia State UniversityExecutive OfficesAttorney General and Department of Law9/30/19 Quarterly 301001120000010000000120000200Department of Accounts
IN PROGRESSOnScheduleDelayedFinanceDepartment of AccountsDepartment of the TaxationDepartment of the TreasuryHealth and Human ResourcesDepartment of Behavioral Health andDevelopmental ServicesDepartment of HealthDepartment of Medical Assistance ServicesDepartment of Social ServicesIndependent AgenciesState Corporation CommissionPublic Safety and Homeland SecurityDepartment of CorrectionsDepartment of State PoliceVirginia Alcoholic Beverage Control AuthorityTransportationDepartment of Motor VehiclesDepartment of TransportationTOTALS9/30/19 Quarterly tment of Accounts
Status of Prior Audit FindingsThe policy governing the Agency Response to APA Audits requires follow-up reports on agencyworkplans every quarter end until control findings are certified by the agency head as corrected.The status of corrective action information reported by agencies under this policy is included inthis report.It is important to note that the status reported is self-reported by the agencies and will be subjectto subsequent review and audit.The first two digits of the finding number are the fiscal year audited in which the finding occurred.The next two digits represent the number of the finding that occurred in the year audited. Multiplefinding numbers for one finding represent repeat findings.AdministrationDepartment of General Services (DGS)Audit Year: 2018Finding 18-02*: Improve Preparation Procedures for Attachment 11Status: No updated Corrective Action Workplan received.Status Summary: In Progress (Delayed)Audit Year: 2015Finding 15-01: Improve Information Security ProgramStatus: No change in the Deliverable date of December 31, 2019. Progress continues. The firstaudit is complete and the second will be complete by October 15, 2019.Status Summary: In Progress (Delayed)Department of Human Resource Management (DHRM)Audit Year: 2018Finding 18-01: Improve Controls over Financial ReportingStatus: Deadline established for FY19 has proved to be inadequate to the reporting requirement.A new deadline will be given to the actuary for FY20 to allow ample time for internal review andadjustment before APA’s review timeline.Status Summary: In Progress (Delayed)Finding 18-02: Improve IT Security GovernanceStatus: Corrective action has been completed.Status Summary: Completed (Delayed)Finding 18-03/17-01/16-03/15-03/14-01: Improve Web Application Security Controls. This is aPartial Repeat Finding.Status: DHRM has taken steps to make the necessary changes but these efforts have uncoveredadditional issues that now require further investigation and testing.Status Summary: In Progress (Delayed)Finding 18-04/17-02/16-01/15-01: Improve IT Risk Management and Disaster Recovery Planning.This is a Partial Repeat Finding.Status: Corrective action has been completed.Status Summary: Completed (Delayed)*DOA did not receive an updated Corrective Action Workplan status by the time period required.9/30/19 Quarterly Report15Department of Accounts
Finding 18-05: Review and Document Service Organization Control Reports of Third-Party ServiceProvidersStatus: Finance has a draft review procedure that will be finalized by October 15, 2019. SOCReports by Service organization vendors are usually finalized towards the end of October.Status Summary: In Progress (Delayed)Audit Year: 2017Finding 17-04: Improve Vulnerability Identification and Mitigation ProcessStatus: Corrective action has been completed.Status Summary: Completed (Delayed)Finding 17-05: Improve Database and Application SecurityStatus: DHRM has taken steps to make the necessary changes but these efforts have uncoveredadditional issues that now require further investigation and testing.Status Summary: In Progress (Delayed)Commerce and TradeVirginia Employment Commission (VEC)Audit Year: 2018Finding 18-01/17-03/16-03/15-06: Continue to Improve Oversight over Third-Party ServiceProviders. This is a Repeat Finding.Status: Two third-party service providers have completed the ECOS assessments, a third provideris in the process of finalizing ECOS Terms and Conditions.Status Summary: In Progress (On Schedule)Finding 18-02/17-02/16-02/15-03/14-03: Completed IT Risk Assessments and Define SystemBoundaries. This is a Repeat Finding.Status: Two third-party service providers have completed the ECOS assessments, a third provideris in the process of finalizing ECOS Terms and Conditions.Status Summary: In Progress (On Schedule)Finding 18-03/17-04: Continue to Improve Database Security. This is a Repeat Finding.Status: VEC has partially implemented controls to address this finding and are working towardsfinalization of those controls.Status Summary: In Progress (On Schedule)Audit Year: 2016Finding 16-10/15-05: Document Separation of Duties of Individuals for Mission Critical Systems.This is a Repeat Finding.Status: VEC is working on a Separation of Duties (SoD) matrix for each mission essential system.Estimated completion date remains December 31, 2019.Status Summary: In Progress (On Schedule)9/30/19 Quarterly Report16Department of Accounts
EducationDepartment of Education (DOE/COO and DOE/DAPE)Audit Year: 2018Finding 18-07/17-11/16-06: Continue Improving Database Security. This is a Repeat Finding.Status: The agency has worked with VITA’s Service Provider Atos to ensure that all of the agency’sservers are being actively monitored by the Commonwealth’s Security Information and EventManagement (SIEM) tool. The SIEM tool has the ability to monitor various events includingmodifications to log files. Atos is currently testing the tool’s ability to monitor root/administrativeactions taken on log filers.
Confirm Virginia Retirement System Snapshot Timely 5. Properly Report Accruals Northern Virginia Community College 1. Follow Commonwealth Requirements for the Stewardship of Fixed Assets. . Improve Reporting to National Student Loan Data System. This is a Repeat Finding. Piedmont Virginia Community College 1. Improve Controls over Fixed Asset .
