Audit 14489

2023-008: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Allowable Activities, Allowable Costs, and Period of Performance Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. Condition: The Office of the County Manager, did not have internal controls established over the direct payments made to participants of the Emergency Rental Assistance Program. Cause: The Office of the County Manager did not have an internal control policy to require segregation of duties in the preparation and review of payments made to participants in the Emergency Rental Assistance Program. Effect: Payments could be made to program participants for inaccurate amounts. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 payments to direct participants out of a population of 605 payments were selected for testing. For 21 payments made there was no documented internal controls over the payments made to participants in the Emergency Rental Assistance Program. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager implement internal control policies to require segregation of duties in the preparation and review of payments to participants prior to disbursement. Views of Responsible Officials: Management agrees with the finding.

2023-009: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. Condition: The Office of the County Manager, did not have internal controls established over the determination of eligibility of the participants in the Emergency Rental Assistance Program. Cause: The Office of the County Manager did not have an internal control policy to require segregation of duties in the preparation and review of the determination of eligibility of participants in the Emergency Rental Assistance Program. Effect: Participants could be deemed eligible that do not meet requirements. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 participants out of a population of 275 participants were selected for testing. For all 60 participants selected for testing, there was no documented internal controls over the determination of eligibility for participation in the Emergency Rental Assistance Program. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager implement internal control policies to require segregation of duties in the preparation and review of eligibility determinations of program participants. Views of Responsible Officials: Management agrees with the finding.

2023-010: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Reporting Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly ERA Compliance Reports that contain ERA 1 and ERA 2 costs incurred during the covered period and households served during the covered period to Treasury Office of Inspector General. Critical information includes: • Administrative Costs Ratio – total obligations and/or expenditures for administrative costs does not exceed the relevant threshold of the total allocation (10% across the prime and all subrecipients for ERA 1, not to exceed 15% of ERA 2 across prime and all subrecipients). • Housing Stability Services Ratio – total obligations and/or expenditures for housing stability services is not greater than 10% of the total amount allocated. • System for Prioritizing Assistance – the number of households with less than 50% Area Median Income (AMI) receiving financial assistance is greater than the number of households with greater than 50% AMI receiving assistance. • Participants Households at Certain Income Levels Eligibility – Total households receiving assistance is not greater than the sum of AMI banded eligible households with 5 to 10% margin of error to avoid false positive for medium to large recipients. Condition: Some expenditures reported did not agree to underlying supporting documentation. The Office of the County Manager did not have internal controls established over the review of Quarterly Compliance Reports. Cause: The Office of the County Manager did not have internal controls established to ensure the Quarterly Compliance Reports agreed to internal supporting documents. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None. Context/Sampling: A nonstatistical sample of four Compliance Reports from a population of six was selected for testing. System for prioritizing assistance, participant households at certain income levels eligibility, and housing stability services ratio did not agree to underlying supporting records. The cumulative impact is as follows: ERA 2 Reporting Period Ended September 30, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 55 households, amount per supporting records is 47 households. Participants households at certain income levels: total households serviced was reported as 61 households, amount per supporting records is 51 households. Total obligations and/or expenditures for housing stability services was reported at $27,515, amount per supporting records is $0. ERA 2 Reporting Period Ended December 31, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 62 households, amount per supporting records is 30 households. Participants households at certain income levels: total households serviced was reported as 68 households, amount per supporting records is 35 households. Total obligations and/or expenditures for housing stability services was reported at $25,083, amount per supporting records is $0. ERA 1 Reporting Period Ended December 31, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 596 households, no supporting records were maintained for this amount. Participants households at certain income levels: total households serviced was reported as 725 households, no supporting records were maintained for this amount. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure quarter Compliance Reports agree to underlying supporting documentation. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-012: U.S. Environmental Protection Agency Passed through State of Nevada Department of Conservation and Natural Resources Clean Water State Revolving Funds, 66.458 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 66.458 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Contracts were missing required provisions per Appendix II to Part 200 for contracts under federal awards. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts included required contract provisions. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 4 procurement transactions out of 4 was selected for testing, including 4 contracts subject to Appendix II to Part 200. All 4 contracts were missing certain required provisions from Appendix II to Part 200. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts include all required contract provisions Views of Responsible Officials: Management agrees with the finding.

2023-011: U.S. Department of Health and Human Services Passed through State of Nevada Division of Child and Family Services Foster Care – Title IV-E, CFDA 93.658 Reporting Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly CB-496 reports that contain current expenditures and information on children assisted for the covered period. Critical information includes: • Part 1, Expenditures, Estimates and Caseload Data • Part 2, Prior Quarter Expenditure Adjustments • Part 3, Foster Care, Adoption Assistance and Guardianship Demonstrating Projects Condition: Some amounts reported did not agree to underlying supporting documentation. Cause: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports agreed to underlying supporting records. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None. Context/Sampling: A nonstatistical sample of two Compliance Reports from a population of four was selected for testing. Average monthly child count did not agree to underlying supporting documentation. The cumulative impact is as follows: CB-496 for the Quarter ended September 30, 2022 Number of Children In-Placement: Title IV-E Maintenance Payments – Foster Family Home: amount reported as 282, amount supported by underlying records is 257. Repeat Finding from Prior Year(s): No Recommendation: We recommend HSA enhance internal controls to ensure the amounts reported agree to underlying supporting records. Views of Responsible Officials: Management agrees with the finding.

2023-008: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Allowable Activities, Allowable Costs, and Period of Performance Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. Condition: The Office of the County Manager, did not have internal controls established over the direct payments made to participants of the Emergency Rental Assistance Program. Cause: The Office of the County Manager did not have an internal control policy to require segregation of duties in the preparation and review of payments made to participants in the Emergency Rental Assistance Program. Effect: Payments could be made to program participants for inaccurate amounts. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 payments to direct participants out of a population of 605 payments were selected for testing. For 21 payments made there was no documented internal controls over the payments made to participants in the Emergency Rental Assistance Program. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager implement internal control policies to require segregation of duties in the preparation and review of payments to participants prior to disbursement. Views of Responsible Officials: Management agrees with the finding.

2023-009: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. Condition: The Office of the County Manager, did not have internal controls established over the determination of eligibility of the participants in the Emergency Rental Assistance Program. Cause: The Office of the County Manager did not have an internal control policy to require segregation of duties in the preparation and review of the determination of eligibility of participants in the Emergency Rental Assistance Program. Effect: Participants could be deemed eligible that do not meet requirements. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 participants out of a population of 275 participants were selected for testing. For all 60 participants selected for testing, there was no documented internal controls over the determination of eligibility for participation in the Emergency Rental Assistance Program. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager implement internal control policies to require segregation of duties in the preparation and review of eligibility determinations of program participants. Views of Responsible Officials: Management agrees with the finding.

2023-010: U.S. Department of Treasury COVID-19, Emergency Rental Assistance Program, 21.023 Reporting Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 21.023 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and terms and conditions of the federal awards. The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly ERA Compliance Reports that contain ERA 1 and ERA 2 costs incurred during the covered period and households served during the covered period to Treasury Office of Inspector General. Critical information includes: • Administrative Costs Ratio – total obligations and/or expenditures for administrative costs does not exceed the relevant threshold of the total allocation (10% across the prime and all subrecipients for ERA 1, not to exceed 15% of ERA 2 across prime and all subrecipients). • Housing Stability Services Ratio – total obligations and/or expenditures for housing stability services is not greater than 10% of the total amount allocated. • System for Prioritizing Assistance – the number of households with less than 50% Area Median Income (AMI) receiving financial assistance is greater than the number of households with greater than 50% AMI receiving assistance. • Participants Households at Certain Income Levels Eligibility – Total households receiving assistance is not greater than the sum of AMI banded eligible households with 5 to 10% margin of error to avoid false positive for medium to large recipients. Condition: Some expenditures reported did not agree to underlying supporting documentation. The Office of the County Manager did not have internal controls established over the review of Quarterly Compliance Reports. Cause: The Office of the County Manager did not have internal controls established to ensure the Quarterly Compliance Reports agreed to internal supporting documents. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None. Context/Sampling: A nonstatistical sample of four Compliance Reports from a population of six was selected for testing. System for prioritizing assistance, participant households at certain income levels eligibility, and housing stability services ratio did not agree to underlying supporting records. The cumulative impact is as follows: ERA 2 Reporting Period Ended September 30, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 55 households, amount per supporting records is 47 households. Participants households at certain income levels: total households serviced was reported as 61 households, amount per supporting records is 51 households. Total obligations and/or expenditures for housing stability services was reported at $27,515, amount per supporting records is $0. ERA 2 Reporting Period Ended December 31, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 62 households, amount per supporting records is 30 households. Participants households at certain income levels: total households serviced was reported as 68 households, amount per supporting records is 35 households. Total obligations and/or expenditures for housing stability services was reported at $25,083, amount per supporting records is $0. ERA 1 Reporting Period Ended December 31, 2022 System for prioritizing assistance: households with less than 50% AMI was reported as 596 households, no supporting records were maintained for this amount. Participants households at certain income levels: total households serviced was reported as 725 households, no supporting records were maintained for this amount. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure quarter Compliance Reports agree to underlying supporting documentation. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures and Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Condition: The assistance listing number was not communicated to the subrecipient at the time of disbursement. Cause: The Office of the County Manager did not have adequate internal controls to ensure subrecipient monitoring requirements were followed. Effect: Noncompliance at the subrecipient level may occur and not be detected by the County. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 12 out of 60 subrecipient transactions were selected for testing. For all 12 transactions tested the assistance listing number was not communicated to the subrecipient at the time of disbursement. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County Managers office enhance internal controls to ensure subrecipient monitoring requirements are followed. Views of Responsible Officials: Management agrees with the finding.

2023-005: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Executed contracts were not obtained from the vendor and certain contracts were not appropriately reviewed by management prior to entering into the agreement. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts were properly executed and were reviewed prior to entering into the agreement. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 874 was selected for testing, including 15 contracts subject to Appendix II to Part 200. One contract was not fully executed by the vendor and two transactions were not appropriately reviewed prior to procuring goods or services. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts are fully executed and transactions are appropriately reviewed in accordance with County policies. Views of Responsible Officials: Management agrees with the finding.

2023-006: U.S. Department of Treasury COVID-19, Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly Project and Expenditure Reports that contain CSLFRF costs incurred during the covered period to the Treasury Office of Inspector General. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue loss calculation validation • Capital expenditures – quantifiable objective criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than $1 million and less than $10 million; or, the recipient submitted the required justification to Treasury if (1) a project has total capital expenditures enumerated by Treasury in the Final rule; or (2) the total of a projects capital expenditures costs is greater than $1 million for capital expenditures not enumerated by Treasury in the final rule. Condition: Written justification was not maintained for capital projects with expenditures that exceeded $1 million and amounts reported for cumulative obligations did not agree to underlying support. Cause: The Office of the County Manager did not have adequate internal controls to ensure proper documentation was maintained for reporting requirements. Effect: Amounts reported to the Department of Treasury for capital expenditures may not have written justification. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 2 out of 4 quarterly reports were selected for testing. For both quarters selected, written justification for capital projects with expenditures exceeding $1 million was not maintained. Cumulative obligations for reported for the period ended September 30, 2022 were under reported by $1,510,426. Cumulative obligations reported for the period ended March 31, 2023 were underreported by $178,671 and cumulative expenditures reported for the period ended March 31, 2023 were underreported by $27,735. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure appropriate documentation to support reporting is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-007: U.S. Department of Treasury COVID -19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires Washoe County to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The Washoe County Comptroller’s Office did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Effect: Prior to correction, federal expenditures were overstated by $1,238,463 and amounts passed through to subrecipients were overstated by $269,766. Questioned Costs: None. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Comptroller’s office enhance internal controls to ensure federal expenditures and payments to subrecipients are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with the finding.

2023-012: U.S. Environmental Protection Agency Passed through State of Nevada Department of Conservation and Natural Resources Clean Water State Revolving Funds, 66.458 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 66.458 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires contracts contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Contracts were missing required provisions per Appendix II to Part 200 for contracts under federal awards. Cause: The Washoe County Office of the County Manager did not have adequate internal controls to ensure contracts included required contract provisions. Effect: Contractors may not be aware of required terms and conditions. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 4 procurement transactions out of 4 was selected for testing, including 4 contracts subject to Appendix II to Part 200. All 4 contracts were missing certain required provisions from Appendix II to Part 200. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Office of the County Manager enhance internal controls to ensure that contracts include all required contract provisions Views of Responsible Officials: Management agrees with the finding.

2023-011: U.S. Department of Health and Human Services Passed through State of Nevada Division of Child and Family Services Foster Care – Title IV-E, CFDA 93.658 Reporting Significant Deficiency in Internal Control over Compliance and Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. Washoe County must submit quarterly CB-496 reports that contain current expenditures and information on children assisted for the covered period. Critical information includes: • Part 1, Expenditures, Estimates and Caseload Data • Part 2, Prior Quarter Expenditure Adjustments • Part 3, Foster Care, Adoption Assistance and Guardianship Demonstrating Projects Condition: Some amounts reported did not agree to underlying supporting documentation. Cause: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports agreed to underlying supporting records. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None. Context/Sampling: A nonstatistical sample of two Compliance Reports from a population of four was selected for testing. Average monthly child count did not agree to underlying supporting documentation. The cumulative impact is as follows: CB-496 for the Quarter ended September 30, 2022 Number of Children In-Placement: Title IV-E Maintenance Payments – Foster Family Home: amount reported as 282, amount supported by underlying records is 257. Repeat Finding from Prior Year(s): No Recommendation: We recommend HSA enhance internal controls to ensure the amounts reported agree to underlying supporting records. Views of Responsible Officials: Management agrees with the finding.